HMRC’s transfer pricing windfall: one-off or new normal?

In an article for Tax Journal, Partner Gideon Sanitt, Transfer Pricing Lead Wai Wan and Transfer Pricing Senior Manager Bahar Eken discuss the factors behind the sharp increase in HMRC’s transfer pricing yield last year, and how it may influence HMRC’s mindset and approach to future transfer pricing enquiries.

HMRC’s transfer pricing yield nearly doubled to a record-breaking £3.4bn in 2024/25, but what is behind the surge? While the statistics suggest a handful of large settlements, beneath the surface there are indications of a systemic shift. With ever-tightening guidance and new reporting requirements on the horizon through the International Controlled Transactions Schedule, HMRC’s arsenal of tools to shape taxpayer behaviour on transfer pricing is only growing. For multinational taxpayers, the message is clear: robust transfer pricing documentation, good compliance processes and proactive, but clear-eyed, engagement with HMRC have never been more critical.

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