Transfer Pricing Services

Transfer Pricing services support your UK corporation tax compliance where your company forms part of an international group. If your UK entity transacts with connected overseas companies, HMRC expects pricing to reflect arm’s length principles. As your group grows, the compliance burden and risk increase.

We help you assess whether UK transfer pricing rules apply and ensure your position aligns with your wider international structure.

Enquire

Back to Tax

3000+

companies helped successfully scale to the UK

25+

years of experience

52

employees all under one roof

CIMA & ACA

approved

What can we help you with?

Transfer pricing governs how transactions between companies in the same group are priced for tax purposes. As your UK entity begins trading with overseas group companies, HMRC expects those transactions to follow arm’s length principles and be properly documented.

We support international groups with transfer pricing advice, documentation, and ongoing compliance so your UK operations remain aligned with UK corporation tax rules and global tax frameworks.

Transfer Pricing Advisory

Transfer pricing is often overlooked when a UK subsidiary is first established. However, intercompany transactions directly affect taxable profits and corporation tax liability.

Our advisory support includes:

Assessing whether UK transfer pricing rules apply based on group size and thresholds
Reviewing intercompany transactions such as management fees, recharges and cost allocations
Advising on profit allocation between the UK entity and overseas group companies
Reviewing alignment between operational reality and pricing policy
Advising on UK documentation requirements
Coordinating with specialist economists for economic studies and benchmarking

If you already have a global transfer pricing policy, we assess how that policy applies locally in the UK. If not, we work with specialist partners to develop an appropriate framework.

This reduces the risk of HMRC challenge and unexpected corporation tax adjustments.

Transfer Pricing Agreements and Documentation

Transfer pricing compliance is not only about setting prices. It also requires formal documentation and clear intercompany agreements.

We support with:

Reviewing and aligning intercompany agreements
Drafting or updating service agreements and recharge frameworks
Ensuring profit allocation reflects commercial activity
Coordinating preparation of UK local files
Supporting economic studies through specialist partners
Maintaining ongoing documentation in line with HMRC expectations

Where applicable, we ensure your UK company reflects the correct level of profit based on its functions, assets and risks. This protects your position during corporation tax filings and potential HMRC reviews.

Ongoing Compliance and Monitoring

Transfer pricing must evolve as your UK entity scales.

We provide ongoing support by:

Reviewing changes in business model or activity
Assessing new intercompany transactions
Monitoring compliance with UK transfer pricing legislation
Aligning transfer pricing with annual corporation tax returns

As HMRC scrutiny increases, maintaining consistent documentation and a clear pricing rationale becomes more important. We help you stay ahead of regulatory developments rather than reacting to them. In some cases, intercompany pricing outcomes can flow through to corporation tax filings, which are managed under our Tax services.

Exit and Restructuring Support

If your UK entity restructures, transfers operations or winds down, transfer pricing implications must be considered.

We support with:

Exit pricing reviews
Assessing potential taxable adjustments
Reviewing intercompany balances and settlements
Aligning final profit allocation with commercial substance
Supporting final corporation tax compliance

This reduces exposure to HMRC enquiry after closure or restructuring.

Transfer Pricing for Overseas-Owned UK Companies

We regularly support:

Overseas-owned UK subsidiaries
UK branches of international groups
Scaling businesses introducing new intercompany flows
Groups centralising or relocating functions

Transfer pricing sits within your wider corporation tax and international tax framework. Our role is to ensure your UK compliance reflects your group’s commercial reality and documented policy.

How our Transfer Pricing services work

This structured approach keeps your corporation tax position clear, compliant and aligned with your business objectives.

We determine whether UK transfer pricing rules apply to your group.

We analyse intercompany transactions and existing agreements.

We coordinate documentation and economic support through specialist partners.

We monitor compliance as your UK entity evolves.

How our Transfer Pricing services work

This structured approach keeps your corporation tax position clear, compliant and aligned with your business objectives.

Meet our Head of Finance

Dom Morris

As our Head of Finance, Dom’s role is to oversee the teams that manage the delivery of fully compliant financial processes for our clients, as well as for advising them on the decisions that will help drive their businesses forward. He is responsible for the Finance teams across both the London and Warwick offices.

What Our Clients Say

Trusted by businesses from all around the world.

⭐⭐⭐⭐⭐

We have worked with Goodwille since starting up our UK branch and have nothing but great things to say about the collaboration. The team is always on top regarding delivery and helpfulness and every interaction is smooth and professional. We highly recommend Goodwille!

-EA

⭐⭐⭐⭐⭐

We have been working with Goodwille for the past 3 years, only amazing experiences. They help startups and scaleups that we bring from Nordic countries with their expansion to the UK market. All experts working at Goodwille have a great understanding of advising companies in their market-entry, helping them with every step along the way. We would recommend their services to anyone who needs a trusted partner in the UK market.

-ED

⭐⭐⭐⭐⭐

Nothing is too much trouble, Goodwille are our local UK Finance, HR and Administrative function enabling us to focus on doing our day jobs. We have a great relationship, but it is unobtrusive: we engage when needed, otherwise things just tick over. I have had direct engagement for the last two years as local GM. My organisation used them for at least a year prior to that.

-L

⭐⭐⭐⭐⭐

We have worked with Goodwille for over a year and they have assisted us in our UK launch. They are a valued and trusted partner with a can-do attitude and I would recommend them to any company looking to establish a company the UK market. As well as assisting with local issues Goodwille have excellent structures in place and work seamlessly with our Swedish head office.

-SH

Need help with your Transfer Pricing?

Speak to a specialist today. Get immediate answers to your transfer pricing questions and find out how we can help you get trading quickly.

Get in Touch

Transfer Pricing FAQ’s

What is the arm’s length principal UK?

The arm’s length principle is the standard used by HM Revenue & Customs (HMRC) to ensure that transactions between related or connected parties are priced as if they were between independent third parties. This prevents profit shifting and ensures the correct UK Corporation Tax is paid.

Key points:

Applies to goods, services, royalties, interest, and intra-group financing.
Prices must reflect market conditions and comparable transactions between unrelated parties.
Proper transfer pricing documentation must be maintained to demonstrate compliance.
Non-compliance can lead to tax adjustments, penalties, and interest.

Foreign-owned UK subsidiaries must apply the arm’s length principle to all cross-border transactions to remain compliant with UK transfer pricing rules.

How does transfer pricing reduce tax?

Transfer pricing can affect the amount of UK Corporation Tax a company pays by determining how profits are allocated between related entities. Setting prices for goods, services, or financing at arm’s length ensures that taxable profits are correctly reported in the UK, which can legally reduce tax if structured appropriately.

Key points:

Over- or under-charging between related parties can shift profits to lower-tax jurisdictions, reducing overall tax liability.
HM Revenue & Customs (HMRC) monitors this closely; non-compliant arrangements can trigger adjustments, penalties, and interest.
Proper transfer pricing documentation is essential to support pricing policies and demonstrate compliance.

Foreign-owned UK subsidiaries can use arm’s length pricing and benchmarking studies to optimise tax efficiently while remaining compliant with UK rules.

When does transfer pricing apply in the UK?

UK transfer pricing rules apply whenever a company engages in transactions with a connected or related party, including an overseas parent, subsidiary, or affiliate. HM Revenue & Customs (HMRC) requires that these transactions be conducted at arm’s length to ensure the correct amount of UK Corporation Tax is paid.

Common situations include:

Sale of goods between a UK subsidiary and overseas parent company
Provision of services within a group (e.g., management, IT, or financing services)
Royalties, interest, or licensing fees charged between related entities
Intra-group loans or guarantees

These rules apply to both UK-based and foreign-owned companies. Non-compliance can result in tax adjustments, penalties, and interest.

What are the transfer pricing documentation requirements in the UK?

In the UK, HM Revenue & Customs (HMRC) requires companies with related-party transactions to maintain transfer pricing documentation demonstrating that prices are set at arm’s length. Proper documentation helps avoid penalties and tax adjustments.

Key requirements:

Master file – Overview of the global group, including structure, business activities, and intercompany policies.
Local file – Detailed information on the UK entity’s transactions with related parties, including financials, pricing methodology, and comparables.
Country-by-country report – Required for large multinational groups exceeding certain revenue thresholds, showing profit allocation across jurisdictions.
Supporting evidence – Contracts, invoices, and benchmarking studies justifying transfer prices.

Foreign-owned UK subsidiaries must prepare documentation contemporaneously, typically by the filing deadline of the UK Corporation Tax return, to demonstrate compliance with transfer pricing rules.

What is transfer pricing in the UK?

Transfer pricing refers to the rules that govern how transactions between connected or related parties—such as a UK subsidiary and its overseas parent company—are priced for tax purposes. HM Revenue & Customs (HMRC) requires that these transactions be conducted at arm’s length, meaning the prices should be comparable to what unrelated parties would pay.

Key points:

Applies to goods, services, royalties, and financing arrangements between related entities.
Ensures that profits are fairly allocated between the UK and overseas jurisdictions.
Non-compliance can lead to adjustments, penalties, and interest from HMRC.

Foreign-owned UK companies should maintain transfer pricing documentation and policies to demonstrate compliance, particularly for cross-border transactions.