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Transfer Pricing
Services
We assist organisations with the development and establishment of transfer prices, documentation of policies, and the formulation of responses to tax authority challenges — ensuring full regulatory compliance across borders.
Intercompany transactions require precision.
We deliver the documentation, strategy, and defence to protect your position.
What we do
Expert Transfer Pricing Advisory & Compliance
Transfer pricing — the pricing of transactions between related parties within a multinational group — is one of the most scrutinised areas of international tax. Get it wrong, and you face penalties, adjustments, and prolonged disputes with tax authorities. Get it right, and you protect your group’s profitability while maintaining full compliance.
At Tho Partners, our Transfer Pricing team combines deep technical knowledge of the OECD Transfer Pricing Guidelines, local Nigerian regulations, and international best practice to help multinational enterprises and related-party businesses structure, document, and defend their intercompany pricing arrangements with confidence.
Whether you are establishing a new transfer pricing policy, updating existing documentation, responding to a tax authority challenge, or conducting a compliance health check — we bring the expertise, rigour, and practical insight to protect your position.
Protecting your intercompany transactions through documentation, strategy, and expert advisory.
The Stakes
Why Transfer Pricing Matters
Tax authorities worldwide are increasingly focused on transfer pricing — with tougher documentation requirements, real-time reporting obligations, and more aggressive audit programmes. The consequences of non-compliance are significant.
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Penalties & Surcharges
Non-compliant or inadequately documented transfer pricing exposes your organisation to substantial penalties and interest charges from tax authorities.
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Increased Audit Risk
Related-party transactions without robust contemporaneous documentation are a primary trigger for tax authority audits and detailed investigations.
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Profit Adjustments
Tax authorities may reallocate profits between jurisdictions — resulting in double taxation, unexpected tax liabilities, and cash flow disruption.
WHAT WE DO
Comprehensive Transfer Pricing Solutions
End-to-end transfer pricing services — from policy development and documentation through to audit defence and compliance health checks.
We assist organisations in designing and establishing transfer pricing policies that reflect the economic substance of their intercompany transactions, align with the arm's length principle, and satisfy the documentation requirements of relevant tax authorities. Our policy development work creates a defensible, commercially sound framework that governs how related-party transactions are priced across the group.
Robust transfer pricing documentation is your first line of defence in any tax authority enquiry. We prepare comprehensive, contemporaneous documentation packages that clearly articulate your pricing rationale, demonstrate adherence to the arm's length standard, and meet both local country filing requirements and the OECD's three-tiered documentation approach.
Meeting statutory transfer pricing filing deadlines is a critical compliance obligation for companies with related-party transactions. We manage the preparation and submission of transfer pricing returns and declarations, ensuring accuracy, completeness, and timely delivery — so your organisation remains fully compliant and avoids late filing penalties.
A Transfer Pricing Health Check provides management with an independent, objective assessment of the organisation's current transfer pricing posture — identifying compliance gaps, documentation weaknesses, and pricing risks before they are surfaced in an audit. Our health checks are designed to be practical and action-oriented, delivering clear remediation recommendations.
When your transfer pricing arrangements are challenged by a tax authority, you need experienced professionals in your corner. We provide comprehensive audit support — from managing information requests and preparing technical responses to representing your position in disputes and negotiations with the FIRS and other regulatory bodies.
Our Approach
What Makes Us Stand Out
Transfer pricing is both a technical discipline and a commercial one. Our approach balances regulatory precision with practical business understanding — always focused on outcomes that are defensible, sustainable, and aligned with your commercial reality.
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Specialized Knowledge
Our experts bring deep insight into global and Nigerian transfer pricing rules, crafting policies that fit your unique business needs.
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Meticulous Documentation
We deliver detailed, audit-ready transfer pricing documentation, ensuring transparency and compliance with every transaction.
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Proactive Defense
We’re your ally in audits and queries, offering end-to-end support to protect your pricing strategies with confidence.
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Agile Solutions
We adapt to evolving regulations, keeping your transfer pricing policies compliant and competitive in a changing landscape.
Ready to Strengthen Your Transfer Pricing Position?
Whether you need a policy built from scratch, documentation updated, a health check completed, or audit support — Tho Partners is ready to help.
Let's Collaborate
"At Tho Partners, we help organisations get transfer pricing right — before the tax authority asks them to.."
Questions? You’re covered.
We create tailored policies for your intercompany transactions, ensuring they meet regulatory standards and support your business objectives.
We compile comprehensive records detailing your pricing methods, transactions, and compliance, ready for scrutiny by tax authorities.
Yes, we handle the preparation and submission of statutory returns, ensuring accuracy and timeliness to keep you compliant.
We provide audit support, reviewing your documentation and policies, and crafting responses to defend against tax authority queries.
A Transfer Pricing Health Check is an independent review of your organisation's current transfer pricing documentation, policies, and practices — assessed against current regulatory requirements and best practice. It identifies gaps and risks before they are surfaced in an audit, and provides a clear remediation roadmap to achieve full compliance.
Contact us via the form above or email info@thopartners.com. We'll arrange an initial consultation to understand your group structure, related-party transactions, and current compliance position — and propose a tailored scope of work to address your needs. No commitment is required at the initial stage.