Change description : 2025-12-19 14:34:00: Added new section 2.2.8 in ‘Common compliance risks (part 2)’, covering value chain analysis in functional analysis. Added new section 3.8 in ‘Indicators of transfer pricing policy design risk (part 3)’, which covers risks specific to offshore procurement hubs. Updated ‘Purpose, audience and use’ to reflect legislative changes from Budget 2025, which may affect the context of these guidelines. [Guidance and regulation]
These guidelines are for UK businesses which fall within the scope of UK transfer pricing rules.
These guidelines and examples are designed to clarify and help you understand HMRC’s expectations as you plan and implement transfer pricing compliance approaches. They also set out what HMRC considers best practice compliance and higher risk approaches.
UK transfer pricing compliance risk is a key concern of finance and risk functions within businesses, and their advisers or in-house tax teams. These guidelines are tailored to the different needs of different audiences. This is reflected in the following parts:
Managing compliance risk for UK businesses (part 1) — should be read by those managing UK transfer pricing risk to:
determine the scope of work
build governance, controls and checks
evidence the arm’s length return
Common compliance risks (part 2) — is for specialists and includes:
indicators of higher risk through the compliance process
HMRC recommendations for best practice compliance approaches
how to support and evidence an arm’s length return
Indicators of transfer pricing policy design risk (part 3) — for specialists and covers common risks in transfer pricing design and implementation.
Webinar
Find out more about these guidelines and how they may be used in practice by watching our webinar recording.