HMRC Transfer Pricing Enquiry: Tax Expert Witness UK

HMRC transfer pricing enquiries investigate whether transactions between connected parties were priced at arm's length. The enquiry procedure involves requests for transfer pricing documentation, functional analysis, and comparables data. HMRC's transfer pricing yield increased dramatically in 2025 through more sophisticated enforcement and broader transaction targeting.

Tax expert witnesses review the transfer pricing documentation, assess the method selection and comparables analysis, and produce independent arm's length opinions. Where HMRC proposes adjustments, the expert can challenge the methodology and produce counter-analysis supporting the taxpayer's original pricing.

Advance Pricing Agreements (APAs) can provide certainty for future transactions, but disputes over historical pricing remain common. Expert evidence on arm's length pricing is the primary tool for challenging HMRC adjustments in both enquiry settlement and FTT proceedings.