Guidance

HMRC Transfer Pricing and Profit Diversion Compliance Facility

Find out about the Transfer Pricing and Profit Diversion Compliance Facility, and how to use it to make disclosures of outstanding liabilities for profit diversion.

• From: HM Revenue & Customs
• Published: 10 January 2019
• Last updated: 17 June 2026 — See all updates

Documents

Transfer Pricing and Profit Diversion Compliance Facility

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Annex A: Transfer Pricing and Profit Diversion Compliance Facility registration form

MS Word Document, 35.3 KB

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Annex B: example of evidence log

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Annex C: disclosed arrangements flow chart

PDF, 302 KB, 1 page

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Annex D: UK profit and loss account analysed by transfer pricing policy pre-proposal

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Annex E: staff profile

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Annex F: Relevant Overseas Entities revenue and cost profile

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Details

This guidance explains:

• how to use the Transfer Pricing and Profit Diversion Compliance Facility
• what you should include in a disclosure report
• HMRC indicators of profit diversion risk

Find out more about Diverted Profit Tax.

Published 10 January 2019

Last updated 17 June 2026 — Show all updates

1. 17 June 2026

   Updated guidance to reflect expansion of compliance facility to cover a broader range of transfer pricing risks and inclusion of the new UTPP rules.

2. 10 January 2019

   First published.