OECD Transfer Pricing Compliance for UK Multinationals
Align your transfer pricing documentation with the latest OECD guidelines and BEPS Action 13 requirements.
- Master file & local file preparation
- Benchmarking & arm’s length analysis
- HMRC defence-ready documentation
- Multi-jurisdiction TP consistency
Request Your TP Compliance Estimate
Our transfer pricing specialists will review your documentation needs and provide a clear plan.
End-to-End Transfer Pricing Services
We prepare OECD-aligned transfer pricing documentation that meets BEPS Action 13 and withstands HMRC scrutiny.
TP Documentation Suite
Master file, local file, and CbCR aligned with OECD guidelines
Benchmarking & Analysis
Arm’s length analysis and benchmarking studie
HMRC Defence Files
Documentation structured for HMRC transfer pricing enquiries
Multi-Jurisdiction Consistency
Coordinated TP documentation across all countries
TP Policy Advisory
Review and alignment of intercompany pricing policies
Is Your Transfer Pricing Compliant?
We assess your TP documentation against OECD 2022 guidelines and BEPS Action 13.
- Master file current and complete
- Local files prepared for all jurisdictions
- Benchmarking studies up to date
- Intercompany pricing policies documented
- CbCR aligned with TP documentation
- HMRC enquiry defence files ready
Navigating Transfer Pricing Compliance
1
BEPS Health Check
Assess your group exposure across all 15 BEPS actions
2
Benchmarking & Analysis
Conduct arm’s length analysis and benchmarking
3
Documentation Preparation
Prepare master file, local files, and supporting docs
4
Filing & Submission
Submit CbCR and TP documentation to authorities
5
Ongoing TP Management
Annual updates, reviews, and HMRC defence support
Why Choose Our Transfer Pricing Experts?
Deep TP
Expertise
Aligned with OECD 2022 Transfer Pricing Guidelines
HMRC Enquiry
Defence
Proven track record defending TP positions
Global
Consistency
Coordinated documentation across 40+ jurisdictions
End-to-End TP
Support
From policy review to annual documentation updates
Frequently Asked Questions
What are the OECD Transfer Pricing Guidelines?
The OECD Transfer Pricing Guidelines provide internationally agreed principles for pricing transactions between related entities within multinational groups. They establish the arm’s length principle as the standard, meaning intercompany transactions should be priced as if they were between independent parties. The most recent edition was published in January 2022.
What is the three-tiered TP documentation?
BEPS Action 13 introduced a three-tiered transfer pricing documentation framework: the Master File (group-level overview of global operations and TP policies), the Local File (detailed analysis of material intercompany transactions for each jurisdiction), and the Country-by-Country Report (CbCR) showing revenue, profit, tax, and activity for each jurisdiction.
How often should TP documentation be updated?
Transfer pricing documentation should be updated annually to reflect current year transactions, financial results, and any changes to intercompany arrangements or economic conditions. Benchmarking studies are typically refreshed every 1-3 years, with financial data updated annually. HMRC expects documentation to be contemporaneous and available upon request.
What is BEPS Action 13?
BEPS Action 13 established the standardised approach to transfer pricing documentation and Country-by-Country Reporting. It requires multinational groups with consolidated revenue of EUR 750 million or more to file CbCR with their home tax authority, and mandates the three-tiered documentation structure (master file, local file, CbCR) now adopted in over 100 jurisdictions.
What are the costs for TP compliance support?
Transfer pricing compliance costs depend on the number of jurisdictions, the volume of intercompany transactions, and the complexity of your group structure. We offer modular services from standalone benchmarking studies to full documentation suites. Contact us for a free scoping discussion tailored to your group.