What is transfer pricing?

It refers to the pricing of goods, services, or intellectual property transferred between related entities in different countries

Why do tax authorities care about it?

Transfer pricing affects where profits—and therefore taxes—are reported. Authorities require that prices reflect what independent parties would have agreed ("arm's-length principle").

Do I need documentation even if I'm a small business?

Yes, if you operate across borders or transact with affiliates abroad. Many jurisdictions have thresholds, but best practice is to maintain at least a simplified record of your pricing rationale.

How often should I review my transfer-pricing policy?

Annually, or whenever there's a significant change in your operations, structure, or market conditions.

Transfer Pricing

Why Transfer Pricing Matters

For businesses operating across borders, transfer pricing is one of the most complex—and closely scrutinised—areas of international tax.
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Tax authorities worldwide are increasing enforcement, demanding transparent documentation and arm’s-length pricing between related entities. Poorly designed transfer-pricing policies can result in double taxation, penalties, or costly disputes.

At iCXO, we help multinational groups and growing international businesses develop compliant, practical, and tax-efficient transfer-pricing frameworks aligned with OECD and local regulations.

Our Methodology

Our approach combines strategic planning, expert analysis, and efficient execution to deliver tailored financial solutions that drive growth and stability.

Understand Your Business Model

We begin by analysing your global operations - functions, assets, risks, and value drivers - to map out inter-company relationships and transaction flows.

Design an Arm’s-Length Policy

Using economic and functional analysis, we determine appropriate transfer-pricing methods and profit allocations that align with the arm’s-length principle and business reality.

Document and Defend

We prepare robust, compliant documentation that satisfies local country requirements and is defensible in the event of a tax authority audit.

Monitor and Update

As your operations, markets, or laws change, we help ensure your transfer-pricing framework remains current and risk-resilient.

Expert Financial Planning Assistance

Our financial consulting services provide tailored planning, expert guidance, and strategic solution to long-term success.

Transfer Pricing Documentation

Preparation of Master Files, Local Files, and Country-by-Country Reports (CbCR) aligned with OECD BEPS Action 13.

Benchmarking Studies

Economic comparability analyses using industry databases to establish arm’s-length pricing for goods, services, intangibles, and financial transactions.

Inter-company Agreements

Drafting and reviewing inter-company contracts to support your policies and enhance compliance transparency.

Planning & Structuring

Advice on designing tax-efficient transfer-pricing models for new markets, restructurings, or supply-chain transformations.

Audit Support & Dispute Resolution

Representation and defence during transfer-pricing audits, MAP (Mutual Agreement Procedure), or APA (Advance Pricing Agreement) negotiations.

Operational Implementation

Integrating transfer-pricing policies into daily operations—pricing systems, accounting entries, and management reporting.

Why Choose iCXO?

End-to-End Expertise

From planning and policy design to audit defence.

OECD & Local Compliance

We align with BEPS, HMRC, EU TP Guidelines, and jurisdiction-specific rules.

Commercially Practical

Strategies that balance compliance with operational realities.

Risk Mitigation Focus

Documentation designed to reduce exposure and strengthen audit readiness.

Transfer

Pricing

Why Transfer Pricing Matters