Defensible documentation for complex inter-partner and cross-border transactions

Transfer pricing is not just a concern for multinational companies. UK partnerships, particularly those operating in multiple jurisdictions or within group structures are increasingly subject to scrutiny under HMRC’s transfer pricing regime.

Our Expertise

At BCR we provide robust, tailored transfer pricing documentation for partnerships, ensuring compliance while supporting transparency and commerciality in inter-entity dealings.

Our Approach

UK tax law requires that transactions between connected parties, whether individuals, partnerships, or companies be conducted on an arm’s length basis. Partnerships engaged in cross-border activity, profit allocation between branches or related entities, or shared service arrangements must be able to demonstrate that their pricing is commercially justifiable.

Failing to maintain adequate documentation may result in penalties, interest, or adjustments to taxable income by HMRC. For partnerships with non-resident members or dealings with offshore structures, transfer pricing risk is particularly high.

When to Seek Advice:

• When a partnership has cross-border operations or international partners.
• Where services, loans, or assets are shared between related parties.
• As part of a corporate restructuring or realignment of inter-entity arrangements.
• Prior to HMRC enquiries or group-wide tax risk reviews.

Our Services

We provide support for the following:

• Preparation of UK-compliant Master File and Local File documentation for partnerships.
• Functional and economic analysis of partnership roles, risks, and assets.
• Benchmarking studies to support arm’s length pricing.
• Transfer pricing policy design for Limited Liability Partnerships and family partnerships.
• Advisory on service arrangements, IP cost sharing, and partner remuneration.
• Coordination with personal and corporate tax returns to ensure consistency.

Our Values in Action

Excellence: Accurate and authoritative documentation that meets HMRC expectations.
Delivery: Timely reports aligned with tax return deadlines.
Respect: Confidential handling of sensitive ownership and financial data.
Elegance: Solutions that are clear, consistent, and commercially rational.

Why BCR Pro

• Deep understanding of UK transfer pricing regulations and partnership tax law.
• Practical experience in structuring and documenting inter-entity transactions.
• Integration with our legal, accounting, and personal tax advisory services.
• Trusted by HNW families, private equity structures, and professional practices.