When companies operate in multiple jurisdictions, internal transfer pricing has financial impact and can attract scrutiny from tax authorities. Getting it right is important.
Frontier has provided specialist advice and opinion to the UK tax authority as well as companies and authorities in other OECD jurisdictions.
Our transfer pricing work typically focuses on helping clients understand the economics of business transactions and their key sources of value, as well as the ways we would expect value to be allocated among parties under the ‘arm’s length’ principle.
We favour rigorous economic analysis over rules of thumb. That means we start with the business and the markets in which it operates. We look at the competitive dynamics within markets, the economic value of scarce assets and capabilities, at information and risks, and the implications of these forces for bargaining power and contract design.
Our experience in regulation, dispute support and competition policy means that, in addition to our expertise in economics and the standard toolkits of financial analysis, we can often draw on detailed knowledge of a wide range of sectors.