What is the UK transfer pricing rule?

Under TIOPA 2010 Part 4, related party transactions must be priced as if they were between unconnected parties (arm-length price). If a UK company charges/pays a non-arm-length price, HMRC can adjust the taxable profit.

Are SMEs exempt from UK transfer pricing?

UK SMEs (under 250 employees, under €50m turnover, or under €43m balance sheet) are generally exempt from transfer pricing for UK-to-UK transactions. UK-to-overseas transactions still apply, but HMRC must direct that rules apply.

What documentation is required?

The UK requires "appropriate documentation" (no specific form). From April 2023, large businesses must maintain a Master File and Local File consistent with OECD Chapter V. Penalties for failure: up to £500,000 plus tax-geared additions.

UK Transfer Pricing Rules & Documentation Calculator

Calculate transfer pricing adjustments under UK arm-length principle (TIOPA 2010). SME exemptions, OECD methods (CUP, cost-plus, TNMM), and documentation requirements. UK-specific HMRC APA process overview.

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$ Finance Disclaimer: These calculators are for educational and illustrative purposes only. Results do not constitute financial advice. Consult a licensed financial advisor before making investment or borrowing decisions.

How to Use

Enter the values for the scenario you are assessing. Calculate transfer pricing adjustments under UK arm-length principle (TIOPA 2010). SME exemptions, OECD methods (CUP, cost-plus, TNMM), and documentation requirements. UK-specific HMRC APA process overview. Use the uk transfer pricing result to inform your calculation.

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Frequently Asked Questions

What is the UK transfer pricing rule?

Are SMEs exempt from UK transfer pricing?

What documentation is required?