Reviewing the HMRC consultation on transfer pricing reform

07 August 2023

In a Tax Journal article, Bezhan Salehy and Deep Shah review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.

As part of the proposed reforms announced on Tax Administration and Maintenance Day 2023, the UK government is consulting on potential changes to the UK legislation on transfer pricing, permanent establishments and diverted profits tax. The consultation is the most significant review of the UK’s core transfer pricing legislation since the early 2000s. The government proposes to align the UK legislation taxing the profits of non-residents’ UK permanent establishments more closely with the OECD rules. The consultation also proposes replacing the UK’s diverted profits tax with a "diverted profits assessment" within the corporation tax rules.

Read the article