Significant changes to UK transfer pricing guidelines

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Significant changes to UK transfer pricing guidelines

HMRC has made significant changes to the transfer pricing sections of the Inland Revenue Manuals.

penandpaper150.jpg

Several changes, published August 9, have been made to the existing guidance; new sections have been added, and old sections removed or reworded. HMRC have sought to restructure the chapters into a more user friendly format and provide additional guidance.

This rewrite is welcome as it should help UK taxpayers’ understanding of HMRC's requirements for transfer pricing and how their transactions and documentation may be audited as part of a risk management review or enquiry.


Further commentary on the changes and the new chapters are to follow from principal TPWeek correspondents for the UK, Grant Thornton. (wendy.nicholls@gtuk.com)

more across site & shared bottom lb ros

More from across our site

As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four
As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
Tax teams are responding to usual client demand in the region, albeit with increased working from home flexibility, local sources indicate
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
The Office for Budget Responsibility’s pessimistic pillar two forecast accompanied the UK chancellor’s muted Spring Statement, dubbed ‘as dull as possible’ by one adviser
Digital tax reform is dissolving the old ‘temporal buffer’, forcing systems, institutions, and professionals to adapt as real-time reporting reshapes governance, capability, and compliance
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
Gift this article