UK updates transfer pricing guidelines for compliance

The guidance clarifies the UK administrator’s expectations for compliance with the UK transfer pricing rules and provides practical steps that taxpayers can take to meet these expectations.

The United Kingdom (UK) His Majesty's Revenue & Customs (HMRC) updated its guidance to help with common risks in transfer pricing approaches (GfC7). Since issuing GfC7, HMRC has continued to work on additional guidelines in the area of transfer pricing, the outcome of which is that two new sections were added to GfC7 in December 2025 covering value chain analysis and offshore procurement hubs. Value chain analysis (VCA) Part 2 of GfC7 covers Common Compliance Risks and HMRC have insert...

Sign in below or register now to read the full article

Authors: Phil Roper, Tim Sarson

Published Date: 30 January 2026