Reform of transfer pricing, permanent establishment and Diverted Profits Tax
We welcome views on these proposals to reform the UK’s transfer pricing, permanent establishment and Diverted Profits Tax rules.
Detail
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.
Documents