Transfer Pricing (“TP”), the area of international tax concerned with the pricing of intercompany transactions used to be the focus of PLC boardrooms rather than Private Business, but no longer. The OECD’s Base Erosion and Profit Shifting (“BEPS”) project has raised the profile of TP on tax authorities radars for UK inbounds and UK PLCs as well as privately owned and private equity backed business. As a consequence, we have seen a significant increase in the number of TP audits and challenges on Due Diligence, which can give rise to price chips, TP adjustments, penalties, interest, and reputational risk.
