Regions
The right answer depends on where you're standing.
A transaction always has two sides, and rarely sits in one jurisdiction alone. As a single firm, we assess both sides — one relationship, one answer. Our primary markets include EMEA and APAC, with reach that grows wherever a transaction actually leads.
UK
The UK is where ajiho's specialism was built, and it remains one of the most active jurisdictions globally for transfer pricing disputes — particularly on financial transactions, where HMRC has taken an increasingly assertive position on intercompany financing, guarantee fees, and cash pooling. We bring direct, practitioner-level experience of how HMRC actually approaches these cases — the evidence they expect, the arguments that hold up, and the ones that don't. That experience extends beyond financial transactions too: UK groups navigating broader transfer pricing questions, treasury structures, or finance function gaps find the same depth of market knowledge, built from years working inside the UK tax environment, not just observing it from outside.
Europe
Continental Europe brings its own layer of complexity — EU state aid rules, the Arbitration Convention, and a patchwork of national implementations of OECD guidance that don't always align even where the underlying principle is the same. Financial transactions transfer pricing disputes are becoming more common across the bloc, not less, as tax authorities coordinate more closely and share information more freely. We work across major European markets on financial transactions, transfer pricing, and the treasury and finance function questions that sit alongside them — bringing the same specialist depth wherever the transaction, or the business, actually is.
Nordics
The Nordics have become an increasingly attractive destination for international investment — stable economies, strong credit fundamentals, and a growing base of multinational and PE-backed businesses financing operations across the region. That growth brings more intercompany financing, more cross-border structuring, and more scrutiny from tax authorities like Denmark's SKAT and its Norwegian and Swedish counterparts, who take a genuinely assertive approach to financial transactions transfer pricing. We bring direct, practitioner-level experience of how these authorities actually operate — the evidence they expect, and the positions that hold up. As with the UK, that depth extends beyond financial transactions: transfer pricing more broadly, and the treasury and finance function support that growing businesses in the region increasingly need.
Asia-Pacific
Asia-Pacific is one of the world's most significant financial centres, anchored by hubs like Singapore and Hong Kong for capital, treasury, and intercompany financing across the region. That concentration of financial activity brings a corresponding rise in transfer pricing scrutiny — tax authorities across the region increasingly aligned with OECD guidance, but applying it through their own distinct lens. ajiho is built with this region at its core: incorporated in Singapore, with direct experience extending across Japan, Korea, Vietnam, and the wider APAC market. As the business grows through the region, so does that depth — financial transactions, transfer pricing more broadly, and the treasury and finance function support multinationals operating across APAC increasingly need.
Middle East
The Middle East is the fastest-growing region globally for treasury and transfer pricing activity — sovereign wealth, rapid diversification away from oil revenue, and a wave of multinationals establishing regional treasury centres out of Dubai and the wider Gulf. That growth is outpacing the tax infrastructure built to govern it, which means the rules are still being written in real time, and the businesses moving fastest need advisers who can move with them. We bring the same specialist depth here as everywhere else — financial transactions, transfer pricing more broadly, and the treasury and finance function capability that regional growth increasingly demands.
Different markets, different rules, the same depth throughout. If your transaction sits somewhere on this list — or somewhere it doesn't yet — let's talk.