At Türner & Co., we work exclusively with multinational groups that have UK subsidiaries or permanent establishments. We understand that your head office team is managing global transfer pricing obligations across many jurisdictions. Our role is to support you locally in the UK, giving you peace of mind that your UK documentation is fully compliant.
The UK broadly aligns with the OECD Transfer Pricing Guidelines, so centrally prepared documentation is often a solid foundation. However, the UK does have specific expectations, and we can help review your UK Local File to identify any UK-specific gaps or prepare it for you from scratch. We also advise on customs and tariffs, recognising that transfer pricing issues now often extend beyond tax.
The UK transfer pricing (TP) rules apply to all UK companies that are part of a group which does not qualify as a Small or Medium-Sized Enterprise (SME), and where transactions occur with “connected parties” — typically, other companies in the same group.
The rules apply to all types of intercompany transactions, including:
Your business is exempt from UK transfer pricing rules if it qualifies as an SME.
A Medium-Sized Enterprise can be brought within the rules, if HMRC issues a notification to this effect.
Important: The employee threshold is decisive. If your business has less than 50 (for small) or 250 (for medium) employees, you are outside the scope regardless of your turnover or balance sheet total.
For groups with global turnover over €750 million, the UK requires:
All documentation must be:
Resigning a director is not just a matter of filing a form.
Tϋrner & Co supports multinational groups by:
Additional Considerations
No. If your company meets the SME conditions— TP rules do not apply.
Yes. The UK aligns closely with OECD guidelines, but documents should be tailored to UK-specific activities and must be in English.
We will assess whether the loan terms and interest rates are arm’s length and whether any thin capitalisation issues arise.
Yes. The UK operates a self-assessment regime, and it is the taxpayer’s responsibility to maintain contemporaneous documentation.
Penalties range from fixed fines (GBP 3,000) to tax-geared penalties of up to 100% of the lost revenue, depending on the severity.
UK-to-UK transactions are in scope.
Yes, we can help you apply for an Advanced Pricing Agreement (APA)
For expert support with UK transfer pricing compliance, documentation reviews, and intercompany finance structuring, contact us.
Managing Director
Senior Manager
Head of Direct Taxes
