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ARTICLE · 21 SEPTEMBER 2026

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

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Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.

United KingdomTax
Gideon Sanitt
Gideon Sanitt
Sophie Rhind
Sophie Rhind

Historically, there has been very little transfer pricing litigation in the UK. In fact, since the landmark case of DSG Retail Limited in 2009, only Blackrock HoldCo 5, LLC has determined a substantive transfer pricing issue.

However, there have been a growing number of cases on procedural matters, such as appeals of information notices and applications for closure notices, where the underlying substantive dispute relates to transfer pricing.

Although it is not necessarily the case that all of these underlying disputes will reach litigation, it is certainly evidence of the fact that transfer pricing enquiries are becoming more contentious, with HMRC making extensive requests for information before they will issue a closure notice.

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