Ensuring arm’s length compliance for UK-based group transactions

Failure to prepare appropriate transfer pricing reports can lead to substantial HMRC penalties, increased tax liabilities, and reputational damage. The UK’s transfer pricing regime is robust, and recent years have seen heightened enforcement and greater demands for documentation. Proactive reporting not only defends against HMRC challenges but also strengthens internal governance and clarity over intra-group arrangements.

Our Expertise

In the UK, transfer pricing rules require that transactions between related companies are conducted on an arm’s length basis. This means prices must reflect what would have been charged between independent parties under comparable circumstances.

Our Approach

At BCR, our team of experts support UK-based businesses and multinational groups with preparing comprehensive, HMRC-compliant transfer pricing documentation that withstands scrutiny and supports sustainable tax planning.

When our services are needed:

• Trading or service agreements between UK entities and foreign affiliates
• UK subsidiaries making payments to overseas parents for IP, management, or support services
• UK companies receiving intra-group loans or finance
• Cost recharges between group companies in different countries
• Cross-border restructuring, licensing, or relocation of functions

Our Services

We provide support with the following:

• Functional and risk-based analysis of UK-related group transactions
• Arm’s length benchmarking using UK and global databases
• Preparation of UK-compliant transfer pricing documentation
• Support with Master File, Local File, and UK Country-by-Country Reporting (CbCR) obligations
• Review of intercompany agreements to align with tax and legal principles
• Representation and assistance in HMRC enquiries or audits

Our values in action

Excellence: Clear, evidence-based transfer pricing reports tailored to your group
Delivery: Prompt and organised project execution from start to finish
Respect: Consideration of your commercial structure, risk appetite, and goals
Elegance: We make technical compliance straightforward and accessible

Why BCR Pro

• Experience in complex UK and cross-border group structures
• Joined-up support integrating tax, accounting, and legal perspectives
• Up-to-date compliance with HMRC transfer pricing guidance and OECD standards
• Practical solutions that balance regulatory requirements with commercial reality