How the Transfer Pricing Landscape is Shifting Ahead of

The UK transfer pricing (TP) market is entering one of its most transformative phases in two decades.

With HMRC's launch in April 2025 of a major consultation aimed at reforming the UK’s transfer pricing regime - many of which are designed to align UK rules more closely with international standards and particularly OECD guidelines - businesses are preparing for significant change.

As a specialist recruiter in Transfer Pricing, I've seen first-hand how these developments are driving a huge spike in demand for transfer pricing work across the UK, particularly amongst the mid-tier firms, where more accountancy practices are tapping into a market with strong future trajectory.

Below, I explore how these changes are influencing hiring trends, market dynamics, and the opportunities ahead for both employers and TP professionals as we move towards 2026.

The TP Market Landscape: How Firms Are Responding

Big 4:

Big 4 TP teams continue to grow, but their expansion increasingly reflects deeper specialisation. Dedicated FS TP teams, as well as strong deals-focused TP practices at PwC and Deloitte, ensure they remain leaders in technical capability.

However, the rapid rise of mid-tier practices tapping into the TP market, combined with greater competition on pricing and client service, has led to a more competitive environment than in previous years. While the Big 4 remain dominant in headcount, they no longer hold exclusive access to larger or more complex mandates.

Top 10:

Practices within the Top 10 are at various stages of growth. Top-tier mid -market firms such as BDO and Grant Thornton who have been established for some time, continue to expand at a steady, strategic pace.

Meanwhile, practices with slightly leaner teams are seeing some impressive client wins and strong levels of business growth as they increasingly compete with the Big 4 of larger mandates.

Crucially, their broader capability is now enabling them to advise FTSE clients across all service lines, an area historically dominated by the Big 4.

Mid-Tier Firms:

This is where we’re seeing the most significant surge in hiring. With the proposed removal of the SME exemption and the tightening of small company thresholds, more businesses than ever will fall within the scope of TP rules.

As a result, mid-tier firms are rapidly scaling up their TP offering, and demand for strong TP professionals is at its highest level to date. Businesses are increasingly recognising the importance of TP - not as an optional advisory area, but as a critical compliance function.

Insights from Leading Transfer Pricing professionals:

Susan Vincent, Blick Rothenberg

“The transfer pricing landscape has evolved rapidly in recent years, driven by heightened compliance requirements, BEPS 2.0 initiatives, and greater scrutiny of intangibles and intragroup services. This momentum has continued into 2025, particularly in the UK, following HMRC’s release of consultation documents in April.

Legislative changes are expected soon, with proposals potentially expanding the regime’s scope to include medium-sized enterprises and introducing new related-party data submission requirements through the proposed International Controlled Transaction Schedule.

As a result, UK transfer pricing compliance obligations are anticipated to increase further from 2026. At the same time, businesses’ operating models are evolving in response to technological advancements and increasingly global workforces, adding another layer of complexity to managing transfer pricing.”

Michael Beard, S&W

“Transfer pricing has been under the microscope for a number of years now, but heightened compliance requirements are making it more challenging than ever for businesses to demonstrate a fully compliant approach to transfer pricing.

Master and local file requirements are now commonplace, and the rising requests from tax authorities for transactional data is already allowing a more targeted approach to tackling non-compliance – we expect this to only continue.

This is coupled with the rise in remote working creating new operational structures, which are often untested from a transfer pricing perspective, and perhaps don’t fall neatly within previously issued guidance. This creates subjectivity, and the need for commercially driven, pragmatic solutions to complex cross-border issues.

The answer to all of this is robust documentation, prepared in advance to avoid the threat of hindsight, but understandably many businesses struggle to find the resource required to meet the ever-growing compliance obligations.

Heading into 2026, technology is likely to play a key part in providing the solution. We are seeing growing use cases for AI within transfer pricing and this, alongside the relevant expertise and guidance, can be a powerful tool to improve transfer pricing processes and help develop enhanced documentation.”

Key Legislative Changes Ahead:

1. Removal of SME Exemption

The transfer pricing exemption for medium-sized enterprises is proposed to be removed.
Only small enterprises will retain exemption status, with revised UK-specific thresholds (e.g., turnover below £10 million).
This change targets cross-border profit diversion risks, as HMRC believes medium-sized entities can reasonably comply with TP rules.

2. Introduction of the International Controlled Transactions Schedule (ICTS)

A new reporting requirement for multinational enterprises to disclose cross-border related party transactions to HMRC.
The ICTS aims to improve risk identification and enable targeted compliance activity.

3. Repeal of UK-to-UK Transfer Pricing Rules

Transfer pricing requirements for domestic transactions between UK-resident entities will be repealed.
This simplifies compliance and reflects the reduced risk of tax arbitrage in purely domestic dealings.

4. Reform of Permanent Establishment (PE) and Diverted Profits Tax (DPT)

PE definitions are being updated to align with OECD standards.
DPT will be replaced by a new corporation tax provision for Unassessed Transfer Pricing Profits (UTPP), improving clarity and treaty access.

5. Modernisation of Enforcement Powers

HMRC will gain enhanced powers to counteract abuse and enforce compliance, including broader definitions of associated enterprises and anti-avoidance provisions.

Implications for Businesses:

Medium-sized enterprises must prepare for increased documentation and compliance obligations.
Multinationals should review their cross-border transaction reporting processes in anticipation of ICTS requirements.
Domestic-only groups may benefit from reduced compliance burdens.

So what lies ahead for TP in 2026?

2026 will be a defining year for the UK TP landscape. Legislative changes will widen the compliance net, and with that comes a growing need for highly skilled TP professionals across all firm tiers.

For employers, this means competing for talent in an increasingly active market. For employees, it represents one of the strongest periods of opportunity the UK TP profession has seen in years - from technical advisory to compliance, operational TP, and emerging areas such as technology-enabled TP solutions.

Firms that invest early, whether by growing their teams or strengthening their internal TP capabilities, will be best positioned to navigate the upcoming changes with confidence.

If you’re hiring in the transfer pricing space or exploring your next career move, I’m always happy to help guide you through the market.

About the author

Chris Cheng is an ACA qualified accountant turned specialist tax recruiter, hiring for transfer pricing, corporate tax and M&A tax positions across professional services and boutique advisory firms.

Chris works with a variety of firms including big 4, top 100 accountancy firms, law firms, and boutique accountancy firms in London and key cities across the UK.

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