Further information — next steps, further questions, webinar, legislation and guidance
Updated 18 August 2026
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Next steps
What to do if you have made an error
Due to a greater awareness of common risks in transfer pricing approaches, businesses may identify areas where they need to adjust their filed return to correctly reflect the transfer pricing rules.
We encourage businesses to correct errors in their transfer pricing position after reading these guidelines. Doing so manages exposure to adjustment and potential penalties under enquiry.
Where you discover an error in the calculation of tax arising from the application of the arm’s length principle, you must:
- check if the tax paid in earlier years is also likely to have been incorrect
- recalculate the liability for the year or years in question
Notwithstanding any impact on the ‘go-forward’ Self Assessment, the process for bringing your tax affairs up to date depends on whether the affected returns are within the timeframe for amendment.
If you are within time to make an amendment, amend the return to reflect the increased profits or reduced losses for that period. If you have a Customer Compliance Manager (CCM), inform them of the changes.
If you are not within the timeframe to make an amendment, you should consider the Transfer Pricing and Profit Diversion Compliance Facility to amend the tax position. The facility is for significant or complex Diverted Profits Tax, Unassessed Transfer Pricing Profits, and non-financial transfer pricing risks. You can discuss this option with your CCM or email us at tppdcfqueries@hmrc.gov.uk.
The voluntary disclosure process should be used if neither of the above options suit your circumstances. You can email us at ccgguidelinesforcompliance@hmrc.gov.uk and we will guide you through the voluntary disclosure process. Include GfC7 in the subject field. Where you have a CCM, copy them into the email.
Further questions
If you have any further questions after reading these Guidelines for Compliance, you can contact us by email at: ccgguidelinesforcompliance@hmrc.gov.uk.
Include GfC7 in the subject field. Copy your customer compliance manager (CCM) into the email, if you have one.
Read about the risks of corresponding with HMRC by email.
HMRC cannot give advance clearance on transfer pricing, outside of Advance Pricing Agreements (APA). While we can clarify the meaning of these guidelines, or their relevance to your business, we cannot give forward assurance of the correct transfer pricing position, except through an APA.
Webinar
Find out more about these guidelines and how they may be used in practice by watching our webinar recording.
Legislation and guidance
The main legislation relating to transfer pricing for accounting periods ending on or after 1 January 2023 (and Income Tax years 2023 to 2024 onwards) is at Part 4 Taxation (International and Other Provisions) Act 2010 (TIOPA10). Section 164 TIOPA10 provides that the legislation is to be interpreted in a manner that best ensures consistency with the guidance in the OECD’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 on their website.
For previous periods, apply earlier versions of the OECD transfer pricing guidelines as appropriate. Read INTM421010 — OECD Guidelines for further details.
The main source of guidance relating to transfer pricing is the HMRC international manual guidance INTM410000 — Transfer pricing guidance.
HMRC has introduced a requirement for UK entities that are part of a multinational enterprise group, with consolidated group revenue of €750 million or more, to keep and preserve both master and local file.
This requirement applies:
- for Corporation Tax purposes — to accounting periods beginning on or after 1 April 2023
- for Income Tax purposes — from the 2024 to 2025 tax year
Both the master and local file must be prepared in accordance with the OECD Transfer Pricing Guidelines. The specific requirements are set out in The Transfer Pricing Records Regulations 2023. Further guidance can be found in the international manual INTM450000 — Transfer pricing records.
Customers with feedback should use the ‘further questions’ section.