Financial transactions transfer pricing

Our Financial Transactions Transfer Pricing (FTTP) network offers deep expertise in navigating the complexities of financial arrangements within multinational groups. In an environment characterised by rapid regulatory evolution and heightened scrutiny, we deliver tailored, sustainable solutions that respond to the dynamic nature of financial transactions and the expectations of tax authorities worldwide.

Financial transactions encompass a broad spectrum—from conventional intercompany loans to the pricing of sophisticated derivative instruments, cash pooling arrangements, factoring, and wider treasury operations such as netting, hedging, and foreign exchange management. These transactions are often material in scale and central to the funding, liquidity, and operational needs of multinational enterprises. Recent revisions to the OECD Transfer Pricing Guidelines have intensified the focus on economic substance, the realistic alternatives available to counterparties, and the capacity of entities to assume and manage financial risk.

In response to this evolving landscape, tax authorities have adopted more rigorous approaches to evaluating intercompany loans, guarantees, and treasury activities, challenging both the structure and pricing of such transactions.

We support clients across the full life cycle of intercompany financial arrangements, offering strategic planning and consulting, policy development, the derivation of arm’s-length interest rates, ensuring locally-compliant documentation, managing tax audits and disputes, and leveraging automation and technology to enhance efficiency and governance. Through our integrated approach, we help clients navigate complexity with confidence, ensuring that financial transactions are not only compliant but also aligned with broader business and tax strategies.