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 2025

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

Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
As World Tax unveils its much-anticipated rankings for 2026, we highlight the two Brazilian firms that had a standout year of tier promotions
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
The hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
Gift this article