March 25, 2026
UK - Provides Transfer Pricing and DPT Statistical Framework for Compliance Outcomes
Summary
HM Revenue & Customs (HMRC), in its Transfer Pricing and Diverted Profits Tax Statistics 2024 to 2025 published on March 11, 2026, provides statistical data on transfer pricing and diverted profits tax (DPT) compliance activities, including quantified yield, case volumes, resolution timelines, and administrative metrics relating to international tax risk management.
Key points
Transfer Pricing Yield
The publication reports transfer pricing yield of £3.4 billion for FY2024–25. Comparative figures are presented as £1.8 billion for FY2023–24 and £1.6 billion for FY2022–23.
DPT-related Compliance Yield and DPT Receipts
The publication reports £1.8 billion of yield associated with diverted profits tax (DPT) compliance activity for FY2024–25. This amount reflects compliance outcomes associated with DPT interventions, including additional corporation tax secured as a result of DPT-related enquiries.
Separately, the net amount of DPT receipts is reported as £94 million for FY2024–25.
Settled Transfer Pricing Cases
The number of transfer pricing cases settled is reported as:
143 cases in FY2024–25
128 cases in FY2023–24
151 cases in FY2022–23
Average Case Duration
The average time to resolve transfer pricing cases is reported as approximately 41 months for FY2024–25.
Advance Pricing Agreements (APAs)
The publication reports APA statistics, including:
Average time to reach agreement: approximately 43.9 months
Number of APA applications received during the year
Number of APAs agreed
Number of APA cases in progress at year-end
Mutual Agreement Procedure (MAP)
MAP statistics include:
115 MAP cases resolved in FY2024–25
Average time to close MAP cases: approximately 24.8 months
MAP outcomes categorized as fully relieved, partially relieved, or otherwise resolved
Inventory of MAP cases at year-end
Advance Thin Capitalisation Agreements (ATCAs)
The publication includes ATCA statistics, including:
Number of ATCA cases agreed
Number of applications received
Average time to reach agreement
Number of ongoing cases
Staffing Levels for International Tax Compliance
The publication reports approximately 392 full-time equivalent staff working on international tax risks relating to multinational enterprises, including transfer pricing, diverted profits tax, and other cross-border tax matters.
Scope of Coverage
The statistics cover compliance activities relating to cross-border transactions between connected parties, including transfer pricing enquiries, settlements, APAs, MAP cases, ATCAs, and DPT-related interventions.
Source
HM Revenue & Customs, Transfer Pricing and Diverted Profits Tax Statistics 2024 to 2025 (March 11, 2026)
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Disclaimer:
This content is for general informational purposes only and does not constitute professional advice.
Information provided herein is based on publicly available sources as of the publication date and may be subject to change.
armize consulting | Transfer Pricing