Reform of transfer pricing, permanent establishment and Diverted Profits Tax

This is a technical consultation on draft legislation for the reform of 3 areas of the UK’s international tax rules:

• transfer pricing
• permanent establishment
• Diverted Profits Tax

It follows a policy consultation on these issues in summer 2023.

On this page, you can read:

• consultation document: Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax
• Statement of Practice 1 (2001): treatment of investment managers and their overseas clients
• draft legislation: permanent establishment
• draft explanatory notes: permanent establishment
• draft legislation: transfer pricing
• draft explanatory notes: transfer pricing
• draft legislation: unassessed transfer pricing profits
• draft explanatory notes: unassessed transfer pricing profits

You can also read a tax information and impact note.