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HMRC considers UK transfer pricing secondary adjustments

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HMRC is consulting until 18 August 2016 on whether to introduce a secondary adjustment rule into UK transfer pricing legislation, involving a range of possible methods for the design of the rule. The current UK rules make a primary adjustment involving the application of the arm’s length principle to the price used for tax purposes. The secondary adjustment would apply a tax charge to any excess cash accumulated from non-arm’s length pricing in an overseas company, such as where a payment is made to a tax haven. The OECD’s transfer pricing guidelines allow for secondary adjustments, which a number of other countries use already. See

If the government decides to introduce the rule, legislation will be included in Finance Bill 2017.

Issue: 1311
Categories: News