ICAEW.com works better with JavaScript enabled.

Transfer pricing

Transfer pricing (TP) directly affects the balance of profits and losses made by different parts of a company. Since these parts may be based in different tax jurisdictions, TP has a significant impact on the company’s tax burden.

Most tax regimes require that transfer prices conform to the arm's length principle. This means they should be comparable to what they would be if the transaction were between unrelated parties acting in similar circumstances.

With the rise of multinational enterprises and increasing value of cross-border transactions, TP is of interest to tax authorities at the national and international level. The Organisation for Economic Co-operation and Development (OECD) has introduced guidelines to preserve the tax bases of its member states and avoid double taxation.

Taxpayers and their advisers should keep abreast of the TP guidance applying in their location and to the products in which they deal.

What's on this page?

  • Offical guidance
  • Country profiles
  • Articles and books

Contact the Library

Expert help for your enquiries and research.

E  library@icaew.com

T  +44 (0)20 7920 8620

Official guidance

OECD

Resources for transfer pricing
The OECD’s portal for information and guidance on TP, including overviews of current policy within each of its member states.

Model Tax Convention on Income and on Capital
The basic statement of the arm’s length principle appears in Article 9 of the Convention.

Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2010
Many OECD member states use these Guidelines to shape their national tax policy. The Guidelines includes instructions for measuring the arm’s length price of a transaction.

Base Erosion and Profit-Shifting (BEPS) initiative
A joint project between the OECD and G20 countries aimed at co-ordinating international tax reforms to address global corporate taxation.

UK

Taxation (International and Other Provisions) Act 2010 (TIOPA)
Part 4 of the Act contains the current rules on TP. The interpretation of TP law in the UK is explicitly tied to the OECD Guidelines.

HMRC Guidance
HMRC has published a detailed manual on TP compliance. UK law contains an exemption from TP rules for small and medium-sized enterprises (SMEs).

Country profiles

Web portals

Global Transfer Pricing Explorer Plus
A digital collection of guidance, current practice, legislation and case law from IBFD organised by country and international organisation. Features detailed comparative analysis of TP practices and an extensive document library. Access is restricted to subscribers.

Joint Transfer Pricing Forum (JTPF)
Website from the European Union featuring TP profiles of member states, statistics, and recent changes in EU tax law.

Transfer Pricing Network
Independent web portal for worldwide TP news and resources, including important case law and relevant documents.

Annual guides

Worldwide Transfer Pricing Reference Guide: 2017-18
EY’s country-by-country guide to transfer pricing, with definitions of core concepts and contacts for each jurisdiction.

PKF Worldwide Transfer Pricing Guide 2017/18
Up to date TP information on 98 tax jurisdictions.

World Transfer Pricing
In addition to the leading firms the guide provides brief summaries of tax authorities, rates and current practice in each country. Produced by International Tax Review.

Articles and books in the Library collection

Selected titles

Guide to international transfer pricing
(Kluwer Law, 2017)
An overview of the principles of transfer pricing and best practices for firms, with details of OECD guidelines and international requirements. Includes a checklist for implementing transfer pricing rules.

International transfer pricing journal
(IBFD)
Covers the latest developments in transfer pricing around the world and comments on relevant legal cases. Published six times a year.

Further resources

To find out how you can borrow books from the Library please see our guide to book loans.

You can obtain copies of articles or extracts of books and reports by post, fax or email through our document supply service.

Can't find what you are looking for?

If you're having trouble finding the information you need, ask the Library & Information Service. Contact us by telephone on +44 (0)20 7920 8620, by web chat or by email at library@icaew.com.

ICAEW accepts no responsibility for the content on any site to which a hypertext link from this site exists. The links are provided ‘as is’ with no warranty, express or implied, for the information provided within them. Please see the full copyright and disclaimer notice.