Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.
On 28 April 2025 HMRC released a further consultation on reform to the Transfer Pricing (TP) Permanent Establishment (PE) and Underassessed Transfer Pricing Profits (UTPP) rules – the latter being the proposed replacement for the unloved DPT rules.
In some places these rules meet HMRC’s stated objective of simplification. Many will welcome the ending of UK-UK TP rules when (broadly) no tax is at stake overall. The interaction between loan relationships derivatives and the TP rules has also been tidied up. Finally the repeal of the DPT regime will see the end of some unloved concepts which are only partly replaced in the new UTPP regime.
The...
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Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP rules do not appear to work as intended.
On 28 April 2025 HMRC released a further consultation on reform to the Transfer Pricing (TP) Permanent Establishment (PE) and Underassessed Transfer Pricing Profits (UTPP) rules – the latter being the proposed replacement for the unloved DPT rules.
In some places these rules meet HMRC’s stated objective of simplification. Many will welcome the ending of UK-UK TP rules when (broadly) no tax is at stake overall. The interaction between loan relationships derivatives and the TP rules has also been tidied up. Finally the repeal of the DPT regime will see the end of some unloved concepts which are only partly replaced in the new UTPP regime.
The...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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