There's a new data governor in town and it's reshaping how organisations manage personal data. Alfie Duffen, Charley Wright and Lovelee May Ramel explain how businesses can use the UK’s Data Use and Access Act (DUAA) 2025 to gain a competitive edge.
Cyber security threats are constantly evolving. We’ll work with you to develop and test robust people, process and technology defences to protect your data and information assets.
Working with borrowers and private equity financial sponsors on raising and refinancing debt. We can help you find the right lender and type of debt products.
Our asset recovery fund eliminates downside risk and retains upside potential. The fund can also buy NPLs, distressed debt, judgments, and other awards.
Global non-performing loan enforcement with non-recourse funding – delivering maximum recovery, including hidden assets, and participation in the upside.
As independent private client advisers, we’re experienced in assisting with complex and sensitive matters effectively, from dispute through to recovery.
Regulatory change, pressure on cost management and growth, and increased investment in technology and data are dominating the financial services industry.
Looking for a more fulfilling role in professional services? One where fresh thinking, collaboration and diversity are valued? At Grant Thornton we do things...
At Grant Thornton, we have a culture where talented people thrive – where high performance is not just expected, but enabled. It’s a culture built on clarity, curiosity, and care. One that challenges us to aim higher, where we’re encouraged to make the most of an abundance of resources to fuel our own development, and where we support each other to grow, learn, and succeed.
Included and valued for your difference is how everyone should feel at work. Not just because it’s right, but because we’re all at our best when we’re able to be ourselves.
Our ESG framework enables responsible, sustainable, and ethical operations. We prioritise the environment, our broader societal impact, and our firm's governance to protect the planet, foster inclusivity and wellbeing, support our communities, and bolster our firm's resilience.
Our employability hub is designed to help you feel prepared for the application process, and guide you through the decisions you will need to make throughout.
Whether you are looking to join us straight from school or with a degree, or even looking for some work experience, we have a programme that is right for you.
We've created this hub to provide you with the information you'll need to help inform career discussions with your young people. From whether an apprenticeship is the right route and the application process, to the support they'll receive and future career opportunities, this page will help you guide informed decisions.
We hope you can find all the information you need on our website, but to help we've collated a few of the questions we hear quite frequently when speaking to candidates.
Looking for a more fulfilling role in professional services? One where fresh thinking, collaboration and diversity are valued? At Grant Thornton we do things...
Our advisory practice provides organisations with the advice and solutions they need to unlock sustainable growth and navigate complex risks and challenges.
The tax landscape is evolving, and our clients need us more than ever to navigate the complexities with them. Our firm has seen remarkable growth in recent years and we have set ambitious plans for the future. To achieve them, we're dedicated to developing our internal talent and excited to welcome new team members who want to grow with us.
We strive to ensure our interview process is barrier free and sets you up for success, as well as being wholly inclusive and robust. Learn about our process here.
As an Armed Forces Friendly organisation we are proud to support members of the Armed Forces Community as they develop their career outside of the Armed Forces.
Are you a partner or director, or on track to one of these positions? Are you looking for a more exciting role where you can drive change and help shape the...
The Agile Talent Community is a network of contract professionals given the opportunity to work with valued clients on a project-by-project basis and provided...
Transfer Pricing: At the heart of strategic tax thinking
20 Nov 20254 min read
Transfer pricing sits at the crossroads of tax and business strategy - where a misplaced decimal can reset global profit margins. With regulators sharpening their focus, transfer pricing strategy and analysis are increasingly a priority for businesses operating across borders.
Contents
At our 2025 Transfer Pricing Conference, held in October at our London offices, this shift was evident. Discussions moved beyond traditional arm’s length principles to explore how transfer pricing interacts with broader tax themes - from Pillar Two and global mobility to supply chain strategy and R&D.
The message was clear: transfer pricing is no longer siloed. It’s embedded in the way businesses create, measure, and protect value.
Four takeaways for decision makers
Pillar Two compliance depends on robust transfer pricing
Pillar Two, the OECD’s global minimum tax framework, is often framed as a reporting challenge, but as explored in multiple sessions at the conference, it’s fundamentally a transfer pricing issue. This is because transfer pricing determines the allocation of income and profit across jurisdictions — the very metrics that underpin Pillar Two calculations.
Retrospective TP adjustments can trigger top-up tax liabilities. Inconsistent documentation or weak governance can jeopardise access to transitional safe harbours. And the Country-by-Country Report (CbCR), which underpins Pillar Two compliance, must be “qualified.” This means it should reflect transfer pricing policies embedded in financial statements, not just tax computations.
The takeaway: Pillar Two compliance demands robust, defensible transfer pricing. Businesses must ensure their policies are not only technically sound but operationally implemented and supported by real-time data.
Environmental Taxes: The hidden supply chain disruptor businesses can’t ignore
The video is playing.This video is playing in mini-player mode.
Supply chains are undergoing rapid transformation driven by geopolitical shifts, ESG commitments, and technological innovation. These changes have profound implications for transfer pricing. As ESG pressures mount, the impact of environmental taxes on supply chains is unavoidable, but not all businesses are equally prepared.
Businesses with existing transfer pricing filing requirements are already ahead of the curve, mapping operational changes to tax strategy, ensuring compliance and mitigating risk. However, businesses without these obligations may assume they’re insulated. Yet rising environmental taxes will ripple through supply chains, increasing costs that are ultimately passed on to them.
The takeaway: Whether you file or not, environmental taxes will influence your supply chain strategy. The question is whether you anticipate these changes, or absorb them at a premium.
R&D and intangibles: Substance over structure
The video is playing.This video is playing in mini-player mode.
Intellectual property (IP) and R&D activities are central to value creation, but they also pose some of the most challenging transfer pricing questions. As innovation becomes more dispersed and collaborative, transfer pricing must evolve to reflect the complexity of modern R&D ecosystems.
Tax authorities want to see that profits from IP align with where development, enhancement, maintenance, protection, and exploitation (DEMPE) activities occur.
Interactions at the conference highlighted the risks of flawed valuations that could trigger penalties.
For businesses, this goes beyond just compliance, it’s a strategic imperative. Getting transfer pricing right can protect against risk, support sustainable growth, and ensure that innovation investments deliver their full commercial value.
The takeaway: It’s no longer enough to rely on legal ownership or historical arrangements. Transfer pricing for intangibles must reflect the economic substance of the activities, be supported by strong governance, and be clearly documented.
Global mobility and the dynamic workforce: New risks, new opportunities
The video is playing.This video is playing in mini-player mode.
The rise of remote work, cross-border teams, and flexible employment models has introduced new complexity into transfer pricing. Where employees are located and where decisions are made can affect permanent establishment (PE) risk, tax residence, and the allocation of value through transfer pricing.
Transfer pricing must now account for the dynamic workforce. Functions performed by in-market teams, especially those involved in strategy or customer relationships, may carry more weight in value creation than previously recognised. This has implications for how profits are attributed and how intercompany charges are structured.
The takeaway: Global mobility intersects with personal tax, social security, and corporate compliance. A holistic approach that integrates transfer pricing with payroll obligations to manage risk and optimise outcomes, is needed.
Conclusion
Transfer pricing is no longer just about documentation, it’s about strategy, governance, and resilience. Whether navigating Pillar Two, managing a global workforce, or responding to supply chain shocks, businesses must embed transfer pricing into their broader tax and operational frameworks. Those who treat it as a strategic lever, embedding it into systems, aligning it with business models, and proactively managing risk will not only stay compliant, but gain a competitive edge.
For further guidance, get in touch with the experts:
