Transfer Pricing Expert Evidence
Transfer pricing disputes require expert evidence on method selection, comparables identification and adjustment, and whether related-party pricing was at arm's length. HMRC's transfer pricing yield increased sharply in 2025 through more sophisticated enforcement.
Tax expert witnesses apply OECD-approved methods including CUP, Resale Price, Cost Plus, and TNMM, justifying the most appropriate method for the specific transaction type and functional profile.
Transfer pricing expert reports for complex international structures can require extensive economic analysis and are a significant investment where disputed adjustments run into millions.
| Aspect | Detail |
|---|---|
| Method selection | CUP, Resale Price, Cost Plus, TNMM, and profit split analysis |
| Comparables | Identification and adjustment of comparable uncontrolled transactions |
| OECD BEPS | Compliance assessment against OECD Transfer Pricing Guidelines |
| Documentation | Review of transfer pricing documentation and APA positions |
Frequently Asked Questions
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