Transfer pricing can have serious tax consequences in our increasingly global business world.

Globalisation has led to:

• Strong growth in cross-border trade flows
• Tighter regulations 
• More numerous and complex tax investigations, conducted by specialised teams 
• Higher tax adjustments, which frequently lead to double taxation in the absence of mutual agreement procedures or Advance Pricing Agreements. 
• An increasingly litigious approach to settling transfer pricing audits.

 
Our Practice Areas

• Transfer Pricing and Tax advice: planning and optimisation, mergers and acquisitions, strategic reorganizations, intellectual property and intangibles management. 
• Economic analyses, representation during transfer pricing audits, assistance in drafting documentation (in association with our Commercial department), advice on tax and commercial implications on implementation of transfer pricing policies.  
• Negotiations with tax authorities globally, together with assistance in Competent Authority procedures and Advance Pricing Agreements.

Our Approach

• Multi-disciplinary teams combining our entire tax and legal expertise in a field that requires the involvement of a number of different specialists. 
• Comprehensive analysis of economic issues through a dedicated team of economists with recognized capabilities in transfer pricing, business valuation and managing international projects in these fields, who work closely with the lawyers handling the client’s engagement. 
• International experience through a network of specialists with relevant expertise in the European, American and Asian markets. 
• Support and decision-making assistance in the client’s transfer pricing approach. 
• Practical international experience due to the diversity of cases handled by the firm’s lawyers and economists 
• Recognised expertise in dealing with the tax authorities, both during investigations and in negotiating bilateral and multilateral advance pricing agreements.

Our clients

Major UK, European and International groups with global operations, and foreign groups with operations and headquarters in the UK, in sectors as diverse as financial services, retail, textiles, automobile, luxury goods, medical equipment, high technology, clothing, packaging and pharmaceuticals.

Our team

For each assignment, we put together a specific team including economists and specialists in national taxation, international taxation, sales tax, customs and excise regulations and, when necessary, contracts and intellectual property law. The team is headed by a partner, who is the client’s principal contact point. These teams also work on trans-national cases carried out by CMS.