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HMRC Proposes Overhaul to UK Transfer Pricing Regime: What You Need to Know

The UK’s tax authority, HMRC (His Majesty's Revenue and Customs), has recently released two consultation papers that propose significant reforms to the country’s transfer pricing (TP) regime.

Prateek Dhingra
Prateek DhingraHead of Transfer Pricing, Commenda
Fact Checked May 5, 2025|3 min read
UK

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About the author

Prateek Dhingra

Prateek Dhingra

Head of Transfer Pricing, Commenda

With over 12 years of experience across the UK and India, Prateek is a recognized industry expert in transfer pricing and international tax. He has advised both high-growth startups and global enterprises on structuring cross-border operations, navigating audits, and staying ahead of evolving regulations. His background spans Big 4 consultancies, global expansion firms, and a U.S.-listed media giant-giving him a rare blend of technical depth and commercial insight. At Commenda, he brings this expertise to help companies scale globally with confidence and compliance.

Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.