At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: HM Revenue & Customs (HMRC). Summaries are simplified; check the linked official source before relying on them.
The law
#Transfer pricing is in Part 4 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010 ss. 146-217), with the basic arm's length rule in s. 147 and the participation condition in s. 148. Finance Act 2026 (c. 11, Sch. 6, Royal Assent 18 March 2026) reformed Part 4 for chargeable periods beginning on or after 1 January 2026: s. 164 now treats the OECD Model Tax Convention Article 9 and the OECD Transfer Pricing Guidelines as interpretive aids, new s. 164A exempts most UK-to-UK transactions, and new ss. 148A, 162A and 162B widen the participation condition.
Documentation
#Under the Transfer Pricing Records Regulations 2023 (SI 2023/818), UK entities in an MNE group with consolidated group revenue of EUR 750m or more (the CbC threshold) must keep a Master File and Local File in OECD format for accounting periods beginning on or after 1 April 2023. The Local File should be finalised by the company's return filing date and the Master File by the ultimate parent's return due date. Files are not filed with the return; HMRC can only demand them from the return filing date onward and normally expects them within 30 days of a request. English language. Smaller groups have no prescribed format but must keep records to support an arm's length return.
Methods
#Methods follow the OECD Transfer Pricing Guidelines (2022), with the most appropriate method chosen for each case. No statutory method hierarchy.
Penalties
#TP adjustments are corrections to the self-assessed return, so normal inaccuracy penalties apply (Finance Act 2007 Sch. 24: up to 30% of extra tax if careless, up to 100% if deliberate and concealed). If an in-scope company has not kept or produced its Master File or Local File, any TP inaccuracy is presumed careless unless the company shows it took reasonable care. Failure to keep records can also bring a penalty of up to GBP 3,000 per return. Keeping compliant files is the main form of penalty protection. CbC failures: GBP 300 initial penalty, up to GBP 60 per day while it continues, and up to GBP 3,000 for an inaccurate report (SI 2016/237).
Pillar Two
#The UK has Multinational Top-up Tax (IIR) and Domestic Top-up Tax (QDMTT) for accounting periods starting on or after 31 December 2023, and the UTPR from 31 December 2024. Groups register once within 6 months of their first in-scope period, then file a UK return (with payment) and a GIR or Overseas Return Notification 15 months after each period end, 18 months for the first period, never before 30 June 2026.
Other rules
#Unilateral and bilateral APAs are available under TIOPA 2010 ss. 218-230. SME exemption (TIOPA 2010 s. 166) still applies to most small and medium groups. Corporate interest restriction (TIOPA 2010 Part 10) limits net interest to 30% of tax-EBITDA, with a GBP 2m de minimis. No formal secondary adjustment rule. An International Controlled Transactions Schedule (ICTS), enabled by Finance Act 2026, is planned for accounting periods beginning on or after 1 January 2027 for MNEs above the CbC threshold. Large companies pay corporation tax in quarterly instalments; others pay 9 months and 1 day after period end. CbC notification (no longer required): The annual notification of the UK filing entity was removed by the CbC (Amendment) Regulations 2023. No date to track. International Controlled Transactions Schedule (ICTS), planned: No annual TP form applies for fiscal years ending in 2026. The ICTS filing date is set in draft regulations still under consultation.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Company Tax Return (CT600) Due 12 months after the end of the accounting period. Tax is usually due earlier: 9 months and 1 day after period end, or quarterly instalments for large companies. | 12 months after year end (e.g. Dec 31, 2026) | All UK resident companies and UK permanent establishments chargeable to corporation tax. | GOV.UK: Company Tax Returns |
| 2 | Local File finalised (Transfer Pricing Records Regulations 2023) HMRC guidance expects the Local File to be finalised no later than the return filing date. Not filed; kept ready for request. | With Company Tax Return (CT600) (e.g. Dec 31, 2026) | UK entities in an MNE group with consolidated revenue of EUR 750m or more in the prior period, with at least one material controlled transaction. | HMRC International Manual INTM450050 |
| 3 | Country-by-Country report Due 12 months after the end of the reporting period. Separate annual CbC notifications were abolished from 26 July 2023. | 12 months after year end (e.g. Dec 31, 2026) | UK ultimate parent of an MNE group with consolidated revenue of EUR 750m or more in the prior period, or a UK entity that must file in place of a foreign parent (secondary filing). | HMRC International Exchange of Information Manual IEIM300040 |
| 4 | UK top-up tax return and payment (Multinational and Domestic Top-up Tax) Self-assessment return for Domestic Top-up Tax and Multinational Top-up Tax, due 15 months after period end, or 18 months for the first period the group is registered, and never before 30 June 2026. Tax is payable by the same date. Late filing: GBP 100 if filed within 3 months of the due date, GBP 200 within 6 months, the higher of GBP 200 or 10% of unpaid tax within 12 months, and the higher of GBP 200 or 20% after that. The flat amounts rise to GBP 500 and GBP 1,000 from the third late period in a row (HMRC MTT55440). | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | GOV.UK: Notice 3, Pillar 2 top-up taxes submission of returns |
| 5 | GloBE Information Return or Overseas Return Notification File the GIR with HMRC, or an Overseas Return Notification if the GIR is filed by the parent or a designated filer in a country that exchanges with the UK. Same deadline as the UK return: 15 months, 18 months for the first period, not before 30 June 2026. MTT and DTT apply from periods starting on or after 31 December 2023; the UTPR from 31 December 2024. Late filing: GBP 100 within 3 months of the due date, GBP 200 within 6 months, then GBP 200 plus GBP 60 a day (HMRC MTT55430). | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | GOV.UK: Notice 3, Pillar 2 top-up taxes submission of returns |
| 6 | Master File provided on request HMRC can issue an information notice no earlier than the return filing date. 30 days is the normal reasonable period. The Master File should be updated by the ultimate parent's return due date. Failing to comply with an information notice: GBP 300 penalty, then up to GBP 60 a day. | Within 30 days of a tax authority request | UK entities in an MNE group with consolidated revenue of EUR 750m or more. | HMRC International Manual INTM450050 |
| 7 | Local File provided on request Normally 30 days from an HMRC information notice, issued no earlier than the return filing date. Missing files lead to a presumption of carelessness for penalties. Failing to comply with an information notice: GBP 300 penalty, then up to GBP 60 a day. | Within 30 days of a tax authority request | UK entities in an MNE group with consolidated revenue of EUR 750m or more. | HMRC International Manual INTM450050 |
| 8 | Register for Pillar 2 top-up taxes (one-time) One-time registration with HMRC, due 6 months after the end of the group's first accounting period in scope (30 June 2025 for a calendar 2024 group). Required even if no top-up tax is due. Only applies in the first in-scope year. | One-time: due only for the first year in scope | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | GOV.UK: Report Pillar 2 Top-up Taxes |
Official texts
#- TIOPA 2010 Part 4 (transfer pricing) (Open Government Licence v3.0)
- TIOPA 2010 ss. 218-230 (advance pricing agreements) (Open Government Licence v3.0)
- Transfer Pricing Records Regulations 2023 (SI 2023/818) (Open Government Licence v3.0)
- Taxes (BEPS) (Country-by-Country Reporting) Regulations 2016 (SI 2016/237) (Open Government Licence v3.0)
- HMRC International Manual, transfer pricing records (INTM450000 onward) (Open Government Licence v3.0)