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TP, DPT and UTPP: twists, turns and transformations

Sarah Bond and Benjamin Crompton (Freshfields) examine the draft legislation that amends certain aspects of the rules on transfer pricing and the diverted profits tax.

At a high level the proposed changes to various aspects of the transfer pricing rules including to bring diverted profits tax (DPT) within the corporation tax fold have been well trailed: the first consultation on these proposals was in summer 2023. However the draft legislation published on 28 April 2025 provides our first glimpse at the detail.

This article focuses on explaining the changes to transfer pricing and DPT that would be made by the draft legislation if enacted in its present form. (The changes relating to permanent establishments...

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