United Kingdom: Transfer Pricing

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

HMRC has issued detailed transfer pricing compliance guidelines, emphasizing roles for "UK risk leads" and "transfer pricing specialists" to manage compliance, avoid high-risk approaches, and ensure thorough documentation and functional analysis, reducing audit uncertainties for UK businesses.

Labour's first budget introduces reforms targeting VAT exemptions, non-dom regimes, and tax avoidance, while courts scrutinize tax motive cases, impacting intra-group lending and unallowable purpose rules.