HMRC’s Transfer Pricing compliance expectations

HMRC’s Guidelines for Compliance (GfC) dealing with transfer pricing risks are an important set of documents intended to provide HMRC’s view on the application of complex, widely misunderstood or novel areas of the tax rules to practical situations. Our earlier article, published when the transfer pricing GfC were first released last year, explains what the guidelines cover and includes our initial recommendations on the steps businesses should take as a consequence.

On 11 April 2025, HMRC added a link to the recording of their March 2025 webinar “introducing these guidelines and how they may be used in practice” to the GfC page (please note individuals are required to input their name and email address before navigating to the recording). This recording provides additional insights from HMRC now that the GfC have been in place for a few months and is likely to be of interest to all UK members of multinational groups.

HMRC clarified in their response to questions received at the March webinar some points of particular note:

• HMRC Customer Compliance Managers (CCMs) have been briefed on the GfC and advised that these will be useful to consider as part of the Business Risk Review (BRR+) process when considering approaches to transfer pricing risk. It is therefore advisable that businesses with a CCM should proactively think about how they respond well before their next BRR+ meeting; and
• Considerations about the UK risk lead(s) recommended to be identified to take responsibility for UK transfer pricing compliance. This includes the importance of review by someone very knowledgeable with the facts of the UK business, delegation of certain tasks and having more than one UK risk lead, and good practices around documenting what has been done and by whom.