HMRC’s consultation that closed on 14 August 2023, Reform of UK law in relation to transfer pricing, permanent establishment and diverted profits tax, includes various proposals in relation to transfer pricing. One welcome area of mooted reform is the removal of the dual application of the market value and arm’s length valuation standards to related party intangible transactions. The removal of the dual-standard requirement and the resulting broadening of access to the UK’s advance pricing agreement programme is positive, but bolder reforms such as to the ‘one-way street’ could further improve taxpayers’ access to treaty benefits and thereby the UK’s attractiveness as an investment location.
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HMRC’s consultation that closed on 14 August 2023, Reform of UK law in relation to transfer pricing, permanent establishment and diverted profits tax, includes various proposals in relation to transfer pricing. One welcome area of mooted reform is the removal of the dual application of the market value and arm’s length valuation standards to related party intangible transactions. The removal of the dual-standard requirement and the resulting broadening of access to the UK’s advance pricing agreement programme is positive, but bolder reforms such as to the ‘one-way street’ could further improve taxpayers’ access to treaty benefits and thereby the UK’s attractiveness as an investment location.
If you are not a subscriber, subscribe now to read this content.
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