Transfer pricing disputes

Our transfer pricing disputes services are designed to support you at every stage of the dispute lifecycle, from proactive risk assessment to litigation support. Whether you're facing a tax authority inquiry, or seeking to strengthen your transfer pricing position, our team of seasoned professionals are here to guide you.

We bring together deep technical knowledge, practical experience and a collaborative approach to deliver tailored solutions that align with your business goals. Our services include:

Gain clarity and confidence with an independent review of your transfer pricing policies. Whether you're preparing for an audit or reassessing your current approach, we provide a comprehensive risk assessment and actionable insights to strengthen your position.

We develop robust, evidence-based strategies to manage tax authority enquiries and facilitate effective negotiations. Our team is experienced in handling Mutual Agreement Procedures (MAPs) and Advance Pricing Agreements (APAs), helping you resolve disputes efficiently and avoid double taxation. 

In addition, we can help guide clients through HMRC’s Profit Diversion Compliance Facility (PDCF). This facility offers an opportunity to disclose and resolve transfer pricing issues cooperatively. We assist with every stage of the process - from initial risk assessment and documentation to submission and negotiation - ensuring a transparent and efficient resolution that aligns with your commercial objectives.

Transfer pricing is not an exact science, and disputes can arise even with the best documentation. Our experts in alternative dispute resolution (ADR) help you explore all available avenues for settlement, ensuring your interests are protected while minimising disruption to your business.

When disputes escalate, we stand by your side. Our litigation support services include expert analysis, documentation preparation and testimony. We work closely with your legal team to build a compelling case and support you throughout the litigation process.

At S&W, we combine technical excellence with a practical, business-focused approach. Our clients trust us to deliver solutions that are not only defensible, but also aligned with their broader commercial objectives. We pride ourselves on:

• Experienced professionals: Our team includes former tax authority officials, industry experts and specialist advisors who bring a wealth of practical experience to every engagement
• Client-centric approach: We take the time to understand your business, tailoring our services to your specific needs and risk profile
• Integrated solutions: We collaborate across disciplines to provide cohesive, end-to-end support
• Proactive insight: We don’t just respond to disputes, we help you anticipate and prevent them through strategic planning and risk management