UK Transfer Pricing - how it works
UK Transfer Pricing - how it works
The UK transfer pricing rules are based on the OECD recommendations, requiring taxpayers to compare their actual related party transactions with those that would be made between independent enterprises, that is ‘at arm’s length’. Here, we summarise the latest developments in Transfer pricing and the current UK compliance requirement.
The applicability of the UK transfer pricing rules, and the documentation requirements for those within the rules, are not always clear or obvious. The documentation rules also rely on the taxpayer judging what level, breadth and depth, of documentation is sufficient and reasonable in the circumstances
If you would like to find out more about how we can advise you on transfer pricing policies or documentation, please visit our Transfer pricing services page.
Latest news on Transfer pricing
2025 transfer pricing consultation
The 2024 Budget announced further consultation will take place in ‘Spring 2025’ on transfer pricing, permanent establishments and diverted profits tax.
Certain changes to the definitions and mechanics of the legislation were previously discussed in a consultation in late 2023, which remain on the table in the 2025 exercise. These factors will be of interest primarily outside of wholly owned groups, for example where companies have a group of common shareholders or partnerships are involved.
Other specific factors that will be covered in the 2025 consultation include:
- A potential exemption for UK-UK transactions from the TP rules
- A potential requirement to report cross-border related party transactions to HMRC annually in the form of an ‘international dealings schedule’
- Changes to the treatment of financial guarantees
- Lowering the thresholds for the current exemption for SMEs.
In addition to the consultation, HMRC is reviewing the treatment of cost-contribution arrangements. This is a technical point primarily aiming to address differences in approach between the UK and US tax authorities.