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
On 28 April 2025, the government published two consultations on reforms to the UK transfer pricing rules.
Firstly, following on from a consultation in 2023, the government is taking forward changes to the definitions and mechanics of the legislation for transfer pricing, permanent establishments and diverted profits tax (DPT).
The transfer pricing element of these proposals will:
- Remove the current UK-to-UK transfer pricing rules by creating a specific exemption for such transactions
- Make changes to the “participation condition” (broadening the net of who is covered by transfer pricing, with discretion given to HMRC)
- Overhaul the treatment of loan guarantees (bringing them into line with the OECD), and
- Align the current approaches to pricing ‘market value’ and ‘arm’s length price’ for Intangible Fixed Assets.
The second consultation covers the scope and documentation of UK transfer pricing and includes proposals for:
- A new requirement for to compile and file and “International Controlled Transactions Schedule” on an individual company basis for UK companies and non-UK companies with a UK permanent establishment.
- Restricting the current exemption for Small and Medium-sized Enterprises to ensure that all medium-sized entities are within the rules in future.
In addition to these consultations, 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.