DSG Retail Limited v. the Commissioners for Her Majesty’s Revenue and Customs

On 22 April 2009, the long awaited decision from the United Kingdom’s first substantive transfer pricing case was made public. The Special Commissioners found in favour of HMRC, deciding that the taxpayer’s transfer pricing was not arm’s length and the result was an understatement of UK corporation tax. This article sets out the background to the case and an overview of its findings, and considers some of the potential implications for taxpayers.