11 Feb 2022

The Transfer Pricing Law Review - 5th edition - United Kingdom chapter

Preface by Steve Edge and Dominic Robertson for the fifth edition of The Transfer Pricing Law Review. UK chapter by Steve Edge, Dominic Robertson and Tom Gilliver.

Given their economic importance, transfer pricing rules will be high on the corporate tax agenda (and the broader political agenda) for many years to come, and they are continuing to evolve at a rapid pace. Over the next few years, we expect the following to be among the main areas of focus. First, the transfer pricing impact of the covid-19 pandemic still needs to be worked out by many countries, though the OECD should be commended for publishing clear guidance on this within a few months of the start of the pandemic. Second, a number of countries may see disputes over the extent to which transfer pricing can be used to recharacterise transactions, rather than merely to adjust the pricing of transactions. Third, many countries are strengthening the requirements for contemporaneous transfer pricing documentation, either aligning with the OECD master file or local file model (as in Israel), or potentially going beyond this (as the UK has proposed). Finally, the OECD/G20 project to address the tax consequences of digitalisation continues to work towards agreeing a solution in 2021, which has become more likely following the arrival of the Biden administration in January 2021.

This article was first published in The Transfer Pricing Law Review, Edition 5 (published in July 2021 – editors Steve Edge and Dominic Robertson) and was reproduced with permission from Law Business Research Limited.

The Law Reviews, published by Law Business Research Limited, are guides to developments in various legal practice areas in key jurisdictions. Our partners and associates edit and contribute to a number of these guides which are available in our Law Reviews page.


This material is provided for general information only. It does not constitute legal or other professional advice.

Practices Tax, Tax Disputes
Contact Information
Steve Edge
Partner at Slaughter and May
Dominic Robertson
Partner at Slaughter and May
Tom Gilliver
Associate at Slaughter and May