RFQ FY26-216: Transfer Pricing Analysis

Introduction

Plan Limited (the “Company”) provides support services to its parent company, Plan International, Inc. (“PI Inc”) a not-for-profit corporation registered in the State of New York, U.S.A. The support services provided include business planning, governance, assurance, legal, finance, internal audit, human resources and information technology.

Plan Limited is a company incorporated in England and Wales with its registered office in the United Kingdom. The Company is a central part of Global Hub operations. All operating expenses incurred by the Company are recharged to PI Inc at cost plus 10%.

Background/Context

As per paragraph 21 of Schedule 18 to Finance Act 1998, Plan Limited is required to keep and retain sufficient records to demonstrate that the tax figures are complete and accurate, including in respect of any figures affected by the Transfer pricing rule.

HMRC’s guidance INTM450040 stipulates that:

• Transfer pricing documentation (Master File and Local File) must generally be reviewed and updated annually to ensure functional and economic analyses remain accurate.
• Benchmarking searches for comparable companies should be refreshed annually, with a full new search conducted at least every three years
• Where the business description, functional analysis, and/or description of comparables have not changed significantly they may be carried forward into the following period.
• A functional change will necessitate fresh benchmarking.

Transfer pricing exists between the Company and PI Inc within the context of all operating costs being recharged to PI Inc at costs plus 10%. This arrangement is underpinned by a service level agreement dated 12th December 2000. The Company anticipates that there will be no significant change to its business description or functional analysis in the near future.

Purpose

The Company is required to file its FY25 corporation tax return by 30th June 2026 and ensure the taxable profits are appropriately calculated (refer to schedule 18 Finance Act 1998). The findings on the transfer pricing policy provides assurance of the accuracy of the income figures used in the calculation of the taxable profits.

The Company is seeking to procure a consultancy service to either confirm it’s transfer price based on cost plus 10% has been adequately benchmarked within a reasonable range or otherwise to clearly demonstrate the price point.

Submission of offers

Offers must be received before the deadline specified in the “Request for Quotations”. The offer must be sent via email to Procurement@plan-international.org, with the subject line “RFQ FY26-216: Transfer Pricing Analysis”.

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