Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Transfer pricing definition

What does Transfer pricing mean? Transfer pricing describes the pricing and terms of transactions between connected companies or related persons, and the adjustments needed so taxable profits reflect an arm’s length result. In practice it covers intra-group supplies of goods and services, royalties and other intellectual property charges, financial transactions (loans and guarantees) and cost allocations. In the UK, the arm’s length principle is enacted in Part 4 of the Taxation (International and Other Provisions) Act 2010 and applied by HMRC consistently with the OECD Transfer Pricing Guidelines. In Ireland, materially similar rules are set out in Part 35A of the Taxes Consolidation Act...

UK transfer pricing (pre 1 January 2026): TIOPA 2010 overview—scope, participation, financing ‘acting together’, SME exemptions, documentation and APAs

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGE relating to UK transfer pricing:

At Budget 2025, the government confirmed that it intends to move ahead with a new duty on in‑scope multinationals to submit annual information regarding cross‑border related party transactions and dealings for accounting periods starting on or after 1 January 2027. The detailed rules for the new ‘International Controlled Transactions Schedule’ (ICTS) are expected to be formally issued for technical consultation during spring 2026. A consultation on this measure ran from April through to July 2025. See News Analysis: Budget 2025—Tax analysis—International. This Practice Note reviews the UK transfer pricing rules as they apply to chargeable periods (referred to in this Practice Note for ease and convenience as ‘accounting periods’) commencing before 1 January 2026. Note that the Finance Act 2026 introduced a range of reforms to the UK’s transfer pricing regime, most of which apply for accounting periods beginning on or after 1 January 2026, subject to specified transitional provisions. For wider background on transfer pricing, see Practice Notes: Transfer pricing—what is it? and Transfer pricing—key concepts and principles...

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Web page updated on 22/05/2026

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