Virtually any type of entity can be subject to transfer pricing rules
(and therefore a potential client):
The above entities could be UK entities or overseas entities.
More information is provided at the self-diagnosis
- Joint venture companies
- 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
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'
comments on this page and elsewhere on this website are of a
general nature. It is not practicable in a general review such as
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
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.
TPS nor its affiliates and employees make any representation regarding
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.