Transfer pricing.

Designing, documenting and defending intercompany arrangements that satisfy the arm's-length standard and withstand scrutiny.

What it is

Priced at arm’s length.

Where companies within a group transact with one another, the terms must reflect what independent parties would have agreed — the arm’s-length standard. It is no longer a concern only of the largest multinationals; intercompany pricing now draws scrutiny across the board, and a position that cannot be evidenced is a position at risk.

We design intercompany arrangements that meet the standard, document them so they can be defended, and stand behind them if they are questioned. The aim is pricing that is both commercial and compliant, supported by the evidence a review will ask for.

How we advise

Policy and design

Setting intercompany pricing that reflects the arm’s-length standard.

Documentation

Preparing the records that evidence and defend the position.

Benchmarking

Supporting pricing with the comparables a review expects.

Defence

Standing behind the arrangements under scrutiny.

Important information

The basis on which we advise.

This page is general in nature and does not constitute tax, legal or financial advice. Advice is given only under a formal engagement, on the basis of your specific circumstances.

ORA Black advises on the design, selection and coordination of structures; it does not act as trustee, foundation council member or administrator, and does not hold client assets. Fiduciary, formation and administration services are provided by appropriately licensed and regulated providers. Where regulated financial services are required, these are provided through ORA Black’s partnership with NEBA Private Clients, under the authorisation of the entity licensed in the relevant jurisdiction.

Structure, reviewed properly.

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