Transfer Pricing Expert Witness UK

Transfer pricing disputes arise when HMRC challenges the pricing of transactions between connected parties, arguing that prices were not at arm's length and adjusting taxable profits accordingly. The arm's length principle, enshrined in UK law and the OECD Transfer Pricing Guidelines, requires that related-party transactions be priced as if the parties were independent.

Tax expert witnesses provide independent analysis of comparable uncontrolled transactions (CUTs), profit level indicators, and the most appropriate transfer pricing method for the specific transaction type. With HMRC's transfer pricing yield increasing dramatically in 2025 through more sophisticated enforcement and broader targeting of transactions, independent expert evidence on arm's length pricing is more important than ever.

Transfer pricing expert reports typically address method selection (CUP, Resale Price, Cost Plus, TNMM), comparables identification and adjustment, functional analysis, and OECD BEPS compliance. Reports for complex international group structures can require extensive economic analysis and are a significant investment, but essential where disputed adjustments run into millions.