United Kingdom: Transfer Pricing

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Article
Beyond Cost-Plus: What The OECD's New Approach To Intra-Group Services Means For UK Taxpayers
The OECD has proposed significant revisions to its transfer pricing guidance on intra-group services, expanding practical examples and emphasizing the need for robust documentation to evidence service provision and benefits. While core principles remain unchanged, the updates create potential tensions with HMRC's more prescriptive approach to high-value services, particularly around pricing methodologies and the treatment of shareholder activities.
United Kingdom Tax
M
Macfarlanes LLP
Article
Exemption For Foreign Permanent Establishments Be Made Mandatory
The UK government plans to make the foreign permanent establishment exemption mandatory from January 2027, fundamentally changing how UK companies are taxed on overseas operations. This policy shift, accelerated for oil and gas companies to September 2026, will prevent businesses from using foreign branch losses to offset UK profits while exempting future foreign profits from UK tax. What implications will this have for international business structures, loss relief strategies, and the broader competitivene
United Kingdom Tax
TS
Travers Smith LLP
Article
Close Companies, Open Books: HMRC Consults On New Reporting Requirements For Close Companies
HMRC has proposed sweeping new reporting requirements for close companies that would mandate detailed disclosure of all transactions with participators, extending far beyond the current framework which only captures loans triggering tax charges. The consultation raises critical questions about the burden on privately-owned groups and private equity structures, where intra-group transactions could generate extensive reporting obligations despite no underlying tax liability.
United Kingdom Tax
M
Macfarlanes LLP
Article
Autumn Budget 2024 - International
Pillar Two In October 2021, over 130 countries in the Inclusive Framework reached agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation. In Autumn Statement 2022, it was announced that the Multinational Top-up Tax and Domestic Top-up Tax would be introduced from accounting periods beginning on or after 31 December 2023 and the undertaxed profits rule from accounting periods beginning on or after 31 December 2024. Multinat
United Kingdom Tax
TS
Travers Smith 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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