The reform of three core areas of the UK’s international tax rules is back on the agenda with the Tax Update Spring 2025 measures announced this week with the government now consulting on transfer pricing permanent establishment and diverted profits tax proposals in line with its Corporate Tax Roadmap commitment first announced in a policy consultation under the previous government in 2023.
On transfer pricing the proposal is to make the rules simpler more certain and better aligned with tax treaties. Draft Finance Bill measures include changes to the participation condition which aim to ‘catch all transactions that should be subject to transfer pricing’ the application of the rules to wholly domestic UK transactions and valuation/pricing where transactions involve intangibles.
As regards permanent establishment (PE) rules the government will continue to consider whether to align the UK domestic definition of a PE...
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The reform of three core areas of the UK’s international tax rules is back on the agenda with the Tax Update Spring 2025 measures announced this week with the government now consulting on transfer pricing permanent establishment and diverted profits tax proposals in line with its Corporate Tax Roadmap commitment first announced in a policy consultation under the previous government in 2023.
On transfer pricing the proposal is to make the rules simpler more certain and better aligned with tax treaties. Draft Finance Bill measures include changes to the participation condition which aim to ‘catch all transactions that should be subject to transfer pricing’ the application of the rules to wholly domestic UK transactions and valuation/pricing where transactions involve intangibles.
As regards permanent establishment (PE) rules the government will continue to consider whether to align the UK domestic definition of a PE...
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:
