.jpg)
Transfer Pricing Solutions for UK Fund Management At A Glance
Capabilities and Services
By drawing on the combined expertise and knowledge of specialists in its Transfer Pricing and Securities and Finance Practices, NERA is uniquely positioned to assist in-house practitioners and tax advisors in managing transfer pricing risk and delivering value in this area. Our approach is differentiated by:
- An in-depth understanding of the industry;
- The ability to determine how the value creation process impacts the remuneration that should be paid to different entities;
- Familiarity with advanced analytical techniques; and
- Access to a proprietary database of information taken from N-SAR and SEC filings.
NERA's relevant expertise includes:
- Establishing an arm's length basis for rewarding fund management activities, taking into account any provision of ancillary services;
- Demonstrating that any security or interest granted as part of the consideration payable to a UK fund manager meets the requirement of being brought into the charge at market rates;
- Providing an economic and financial analysis of the net compensation paid to a UK fund manager as part of a series of transactions;
- Analysing and providing economic advice on the overall system of transfer pricing adopted by an investment fund, and designing transfer pricing policies relating to the establishment of on-shore investment management activities;
- Drafting or helping to draft contemporaneous transfer pricing documentation in line with OECD Guidelines and UK requirements; and
- Providing specialist economics and finance input to support a taxpayer's filing position where a tax authority has raised an enquiry.
