United Kingdom: Transfer Pricing

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Article
Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases
Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United Kingdom Tax
M
Macfarlanes LLP
Article
Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case
When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European Union Tax
RPC
Article
UK Tax Authority Will Transform Transfer Pricing Risk Assessment
The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.
United Kingdom Tax
M
Macfarlanes LLP
Article
Autumn Budget 2024 - Business Taxes
The Autumn Budget 2024 introduced key updates on employer NICs and the Corporate Tax Roadmap, aiming to create stability and streamline the tax landscape. Employer NICs will rise from 13.8% to 15% from April 2025, with reduced thresholds expanding liability but partially offset by an increased Employment Allowance. The Corporate Tax Roadmap maintains current corporate tax rates and reliefs while exploring simplifications in capital allowances, support for pre-development costs in renewables and
United Kingdom Tax
TS
Travers Smith LLP
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