Transfer pricing disputes

Approach and deliverables

We map related parties, international transactions, functions, assets and risks to the pricing analysis under challenge. The review examines the data and assumptions supporting the method rather than treating a benchmark range as the whole defence.

Outputs can include an issue matrix, segmental reconciliation, comparable-data questions and a submission draft. The team coordinates specialist economic analysis and the relevant objection or appeal route where required.

Organise the issue matrix by transaction and disputed adjustment. Connect the authority’s position with the method used, the financial inputs and the business facts relied upon, identifying which questions need accounting evidence and which need specialist economic analysis.

Records for the case file

• Related-party agreements and pricing policy
• Transfer-pricing report and accountant report
• Segmental financials and allocation workings
• Notices, orders and comparable-company material

Retain the version of the study and financial workings used in the original submission. Document allocation keys, excluded items and any later corrections so the specialist can reproduce the segmental result and distinguish a changed calculation from a changed business assumption.

A practical example

Where a segment’s costs differ from the statutory accounts, explain the allocation bridge before relying on that segment’s margin in a response.

If shared support costs were allocated using headcount, show the population, period and source of that headcount alongside the cost pool. A later change to the allocation basis should be explained explicitly rather than appearing as an unexplained improvement in the margin.

Engagement boundaries

Database studies, expert reports and advanced dispute-resolution routes are separate scopes. Reviewing the evidence supports our analysis; it does not guarantee that the authority will accept it or reduce an adjustment.

The proposal states the period, procedural stage, drafting and appearance work included. Share the deadline during intake; a public enquiry does not appoint a representative or extend any statutory time limit.

The closing pack identifies the calculations and exhibits actually submitted, specialist inputs still outstanding and questions carried into the next stage. Database access, fresh benchmarking and further representation are agreed separately so the handover is clear about the work completed.