Transfer Pricing

When groups trade across borders, pricing between connected businesses needs to stand up to scrutiny. That means more than ticking a compliance box. It means having a clear, defendable approach that supports your commercial goals, reduces risk and gives you confidence if questions come from HMRC or overseas tax authorities.

At HURST, we provide practical, jargon-free transfer pricing advice with a real commercial edge. Whether you are expanding internationally, reviewing existing arrangements or preparing documentation for the first time, we help you put the right framework in place.

If you have a specific query about transfer pricing, email us at imagine@hurst.co.uk or call 0161 477 2474.

Why transfer pricing matters

Transfer pricing rules are designed to make sure transactions between connected parties are carried out on an arm’s length basis. In practice, that can create real complexity for growing groups, especially where goods, services, intellectual property or financing move between countries.

Getting it wrong can lead to enquiries, penalties, double taxation and unnecessary pressure on internal teams. Getting it right can help you stay compliant, reduce uncertainty and support growth with confidence.

How we can help

Our transfer pricing support is tailored to the size, structure and ambition of your business. We can help with:

• Transfer pricing policy design and review – creating or refining policies that reflect how your group operates in practice.
• Benchmarking studies – supporting the pricing of goods, services, royalties and financing with robust market evidence.
• Documentation and compliance – preparing proportionate, defensible documentation to support your position.
• Intercompany agreements – aligning legal agreements with the commercial and tax reality of your arrangements.
• Risk reviews and health checks – identifying gaps, exposures and opportunities before they become bigger issues.
• HMRC enquiry support – helping you respond clearly and confidently where transfer pricing is challenged.
• International coordination – working with trusted overseas advisers where a joined-up cross-border approach is needed.

Who we work with

We advise a wide range of businesses on transfer pricing, including:

• Owner-managed groups growing overseas
• UK subsidiaries of international groups
• Mid-market businesses with cross-border trading activity
• Groups with intellectual property, shared services or intercompany finance arrangements
• Businesses preparing for investment, acquisition or restructuring

Whether you are dealing with a single intercompany arrangement or a more complex international structure, we will tailor our advice to your situation.

Why choose HURST?

Clear advice, grounded in commercial reality

Transfer pricing can quickly become technical. Our role is to make it clear, practical and useful. We focus on advice that works in the real world, not just on paper.

Proactive support

We help you spot issues early, strengthen your position and avoid problems before they escalate.

A joined-up international view

Transfer pricing rarely sits in isolation. We look at the wider picture, including international tax, compliance, governance and future growth plans.

Advice tailored to ambitious businesses

No off-the-shelf answers. We take time to understand how your group operates so our advice reflects your commercial objectives.

Common transfer pricing scenarios

Businesses often come to us when they need support with:

• charging management fees across a group
• pricing goods sold between territories
• setting royalty rates for intellectual property
• reviewing intercompany loans and financing
• preparing documentation ahead of audit or enquiry
• supporting a new overseas expansion
• aligning transfer pricing with a group restructuring or transaction

Frequently asked questions

What is transfer pricing?

Transfer pricing is the pricing of transactions between connected parties in different parts of the same group, such as the sale of goods, provision of services, licensing of intellectual property or intercompany lending.

Do all businesses need transfer pricing documentation?

Not every business has the same level of documentation requirement, but many groups with cross-border related party transactions need to be able to support how their prices have been set. The right level of documentation depends on your facts, footprint and risk profile.

What is the arm’s length principle?

It means connected parties should price transactions as if they were dealing with each other independently in the open market.

Can HURST help if HMRC has raised questions?

Yes. We can review your current position, help you prepare supporting evidence and work with you to respond to HMRC in a clear and measured way.

Contact us for transfer pricing advice

If transfer pricing is on your agenda, HURST is here to help. We provide practical advice that helps you stay compliant, reduce risk and move forward with confidence.

Email imagine@hurst.co.uk or call 0161 477 2474 to speak to our transfer pricing team.