Skip to main content

UK: Transfer pricing and DPT statistics for FY 2024-2025

Transfer pricing-related compliance yielded a record £3.4 billion.

Share
March 19, 2026

HM Revenue & Customs (HMRC) on 11 March 2026, published their latest Transfer Pricing (TP) and Diverted Profits Tax (DPT) statistics for the year ended March 31, 2025 (FY 2024-2025). The statistics show that:

  • TP-related compliance yielded a record £3.4 billion, £1.6 billion up on the prior year and around £1.2 billion higher than the previous high in FY 2020-2021.
  • DPT-related compliance yielded £1.8 billion, up from £117 million in FY 2023-2024, which likely explains a large part of the increased TP yield.

Other interesting observations from the statistics include:

  • Advance pricing agreements (APAs): Similar numbers of APAs were agreed compared with recent years and average time to conclude APAs improved to 44 months, the shortest since FY 2018-2019.
  • MAP resolution: Performance was strong, with 115 cases concluded in an average of 24.8 months.
  • Profit diversion compliance facility (PDCF): There were fewer new PDCF letters and new registrations for the PDCF. 17 cases were resolved indicating that HMRC had largely cleared their case inventory from earlier years by March 31, 2025. HMRC have since issued new PDCF letters and received new registrations.
  • DPT notifications: HMRC received 42 DPT notifications in FY 2024–2025, almost double the average number for the previous four years. This is notable as DPT is due to be repealed and replaced by the unassessed transfer pricing profits rules, which do not have equivalent notification obligations.

Read a March 2026 report prepared by the KPMG member firm in the UK

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.

KPMG. Make the Difference.


Some or all of the services described herein may not be permissible for KPMG audit clients and their affiliates or related entities.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. KPMG LLP does not provide legal services.

The information contained herein is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

© 2026 KPMG LLP, a Delaware limited liability partnership, and its subsidiaries are part of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit https://home.kpmg/governance.

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

By submitting, you agree that KPMG LLP may process any personal information you provide pursuant to KPMG LLP's . Privacy Statement

An error occurred.

Job seekers

Visit our careers section or search our jobs database.

Search now!

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Submit

Office locations

View locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Learn more

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Contact

Headline