UK Transfer Pricing and Diverted Profits Tax 2024-25: HMRC statistics, insights and business implications

Overview of HMRC’s 2024-25 Transfer Pricing and DPT statistics

On 11 March 2026, HMRC published its annual statistics on transfer pricing (TP) and diverted profits tax (DPT) covering the 2024-25 UK tax year (6 April 2024 to 5 April 2025). Read more in the HMRC publication on transfer pricing.

Why Transfer Pricing remains a key compliance focus for HMRC

These statistics reinforce that TP remains a key focus area for HMRC and emphasises the importance of ensuring intercompany arrangements are compliant with the arm’s length principle and appropriately documented through robust TP documentation and intercompany agreements.

Transfer Pricing and enquiry trends

TP describes the legislation and guidelines used to select and support “arm’s length” prices charged between relevant associated enterprises.

The headline TP statistics are as follows:

• TP yield represents income generated by HMRC through TP enquiries, advance pricing agreements (APAs), advance thin capitalisation agreements (ATCAs) and mutual agreement procedure (MAP) cases. TP yield increased substantially, almost doubling to £3,387m from £1,786m in the prior year. Given HMRC’s recruitment drive for TP specialists, this trend is expected to continue.
• 143 TP enquiry cases were settled in the 2024-25 UK tax year which is an increase from 128 cases settled in the prior tax year. The average time to settle cases has increased from 33.1 to 41 months reflecting increased the complexity in TP enquiries.
• 392 full-time equivalent staff are working on international tax issues including TP which demonstrated ongoing recourse commitment and focus in increasing the TP yield.
• HMRC agreed 26 APAs during the year with an average time to reach APA agreement decreasing from 53 months in the prior year to 43.9 months.
• The number of MAP cases resolved increased from 86 in the prior year to 115 with the average time to resolve such cases decreasing from 28.8 months to 24.8 months.

Diverted Profits Tax: what the 2024-25 numbers show

DPT is an anti-avoidance levy on large multinational enterprises (those with worldwide revenues exceeding €750m) that shift profits out of the UK using contrived arrangements or avoid creating a taxable presence. The net amount of DPT received by HMRC decreased slightly to £94m in the 2024-25 UK tax year from £108m in the prior year.

However, DPT notifications received by HMRC increased from 16 to 42 reflecting an increased number of taxpayers falling within the scope of the DPT legislation (which is now repealed and replaced by the Unassessed Transfer Pricing Profits (UTPP) regime for accounting periods commencing on or after 1 January 2026. The draft legislation is part of UK TP reform and is included in the Finance (No. 2) Bill 2024-26.)

How we can help

We can assist your business in reviewing existing TP policies, designing new ones, preparing supporting TP documentation amongst other TP advisory and implementation services. We can also advise you in navigating recent UK TP developments which we covered in our Autumn Budget 2025 for Businesses article which introduce key legislative changes such as a new International Controlled Transactions Schedule (ICTS) requirement for accounting periods commencing on or after 1 January 2027.

Our TP team have a wealth of experience and regularly work together with other Nexia members on multi-territory projects. Please get in touch with Dawn Ross or Evan Tuck.