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Text © Transfer Pricing
Solutions Limited 2004-7
Types of client

Virtually any type of entity can be subject to transfer pricing rules (and therefore a potential client):
  • Companies
  • Joint venture companies
  • Partnerships
  • Individuals (or groups of individuals) who control companies or partnerships
  • Other legal persons, such as charities and local authorities, that control a company or partnership
The above entities could be UK entities or overseas entities.  More information is provided at the self-diagnosis pages.

Non-UK advice

Clients often want TPS to provide transfer pricing documentation or advice that applies globally, not just in the UK.  This is usually not a problem, as the OECD Transfer Pricing Guidelines lie at the heart not only of the UK transfer pricing rules, but also of the corresponding rules in most other major economies.  Indeed, we have carried out a number of projects that do not involve the UK at all.

As mentioned here, Gareth Green has spent several years working in transfer pricing outside the UK, which provides an invaluable international perspective to bring to bear in carrying out multilateral projects.  Years of working on multi-country projects has also given us a broad knowledge of major transfer pricing issues in other countries, which can be supplemented by the use of local experts where appropriate.


Although branches are taxed under slightly different rules, transfer pricing principles also largely apply to determining the profits attributable to a branch (permanent establishment).  We can assist on this for the following:
  • UK branches of overseas businesses
  • Overseas branches of UK businesses

The 'small print'

The comments on this page and elsewhere on this website are of a general nature.  It is not practicable in a general review such as this to consider every convolution of the UK transfer pricing rules or of any other tax law that may be relevant.  Moreover, these pages naturally do not take into account the specific facts relating to any particular taxpayer.  Therefore, although the guidance in this website should give a good indication of the likely position under the transfer pricing rules, taxpayers should obtain professional advice to verify the position, or carry out their own analysis.

Neither TPS nor its affiliates and employees make any representation regarding the completeness or accuracy thereof and they accept no responsibility for any loss or damage incurred as a result of any user acting or refraining from acting upon anything contained on these pages or upon its omission therefrom.