Financial Transactions Transfer Pricing

Financial transactions transfer pricing

The specialist discipline within transfer pricing — where loans, guarantees, cash pools, and capital structures get priced right.

Transfer pricing on goods, services, and intangibles is one discipline. Pricing the money that moves between related parties — loans, guarantees, cash pooling, capital structure — is another, and it demands specialist depth most generalist tax teams don't carry. We bring that depth: rigorous, defensible pricing that holds up commercially and stands up to tax authority scrutiny, across the full range of intercompany financial arrangements.

Service lines

Credit Rating Analysis

Credit risk underpins everything. We establish defensible standalone credit ratings for intercompany borrowers using rating agency methodologies and all available Chapter X approaches — applied as the context demands.

Intercompany Loan Pricing

No two intercompany loans are the same. Simple or complex, we determine the arm's length interest rate based on the specific facts and circumstances. Where it adds value, we model alternative scenarios to support better commercial decisions.

Cash Pooling

Cash pools create value for the group — the question is how that value is allocated. Physical or notional, we price both sides of the arrangement so your treasury function runs at its full potential.

Guarantee Fees

Guarantee fees are only defensible if the guarantee itself does something — financial or performance. It might improve terms, secure a contract, or reduce risk the market would otherwise price in. We establish exactly what that benefit is, and price the fee to match.

Capital Structure

Where a safe harbour doesn't exist, or isn't appropriate for your business, we go beyond it to meet your commercial needs — and ensure the structure still holds up under the arm's length principle.

Debt Structuring

The way a business is funded has consequences well beyond the balance sheet — tax exposure and commercial flexibility for years afterward. We design that structure, and manage it through repayment, novation, and everything that follows.