Transfer Pricing Advisory Services
Proactive transfer pricing advice — designing arm's-length pricing for related-party transactions, choosing the right method and structuring dealings before they are reported.
Trusted Across Diverse Business Sectors
Where does TP advisory add value?
TP advisory sets the arm's-length position before a transaction happens — so pricing, agreements and documentation all align.
Designing the Position
Choosing method and pricing that reflect the arm's-length principle.
- Method selection
- Margin / price design
- Agreement alignment
Structuring Transactions
Advising on how to structure related-party dealings tax-efficiently and defensibly.
- Services and cost allocation
- Royalty and IP charges
- Intra-group financing
The best transfer price is designed, not reconstructed under notice.
When a related-party price is designed on sound method and comparable logic at the outset, the documentation and 3CEB simply confirm it.
Advisory also shapes how transactions are structured — services, intangibles and financing each need a defensible charging basis.
This work leads naturally into benchmarking and documentation, and connects with international tax.
TP Advisory Focus Areas
Where advisory concentrates.
Transfer pricing advisory work we commonly handle.
Advisory can be one-off for a transaction or ongoing for the group.
Pricing & Method Advice
Choosing the most appropriate method and arm's-length price.
Transaction Structuring
Advising on services, IP and financing arrangements.
Policy Design
Building a group pricing policy that is consistent and defensible.
Pre-Transaction Review
Testing a proposed dealing before it is executed and reported.
Situations where early advice pays off.
New Intercompany Arrangement
The charging basis should be designed up front.
Introducing Royalties or IP
Valuation and method need careful advice.
Intra-Group Financing
Interest and terms must reflect arm's length.
Restructuring the Group
TP consequences should be assessed before change.
Key elements that shape a transfer pricing position.
Function
Understand functions, assets and risks of each party.
Selection
Choose the most appropriate method for the transaction.
Design
Set a price or margin supported by comparable logic.
Agreements
Reflect the position in contracts and documentation.
A structured advisory approach.
Depth depends on the transaction, its value and the group's risk profile.
Understand
Map the transaction, parties and functions.
Analyse
Characterise the dealing and select the method.
Advise
Recommend an arm's-length price and structure.
Align
Reflect it in agreements and pricing policy.
Support
Feed the position into benchmarking and documentation.
TP Advisory / Method Selection Graphic
What helps us give useful TP advice?
A well-designed price is the cheapest defence there is.
Designing the arm's-length position up front means the annual documentation confirms it rather than justifies it after the fact.
Poorly structured intercompany charges — especially IP and financing — are common triggers for adjustment.
Advisory that aligns pricing, agreements and documentation gives the strongest footing at assessment.
Designing a new intercompany arrangement?
Discuss TP AdvisoryWhy groups choose JJJ & Company LLP for TP advisory.
Advisory is strongest when it flows into benchmarking, documentation and defence.
Function-Led Advice
Positions built on real functions, assets and risks.
Structuring Depth
Services, IP and financing handled with care.
Consistent Policy
A group-wide policy that holds across years.
Defence-Ready
Advice designed to survive later scrutiny.
Explore related transfer pricing services.
Common TP advisory questions.
When should we take transfer pricing advice?
How is the transfer pricing method chosen?
Can you advise on royalties and intra-group loans?
Does advisory replace documentation?
Is advisory useful for domestic groups too?
What information do you need to start?
Need to discuss your requirement?
Share a few details and our team can review your requirement and discuss the next step.