International Tax & Transfer Pricing

Businesses that operate across borders face a different tax question in every jurisdiction: what's taxable, where, and under which treaty. Our international tax team advises on cross-border structuring, permanent establishment risk, treaty relief and repatriation strategy, so decisions made in one market don't create unplanned exposure in another.

Transfer pricing sits alongside this work. We help groups set, document and defend arm's-length pricing for intercompany transactions — from policy design through to benchmarking studies and contemporaneous documentation that stands up to scrutiny from tax authorities.

How a typical engagement runs

We typically begin with a jurisdiction-by-jurisdiction map of where the group has people, assets or contracts, since that usually reveals permanent establishment risk before it becomes a dispute. From there we build the treaty and withholding-tax position for each material flow, and set a transfer pricing policy that the finance team can apply consistently without re-litigating it every quarter.

What this covers

• Permanent establishment risk assessment across markets
• Treaty relief analysis and withholding tax optimisation
• Transfer pricing policy design and benchmarking studies
• Contemporaneous transfer pricing documentation
• Repatriation and cash extraction planning