United Kingdom on Transfer Pricing

Pillar Two In October 2021, over 130 countries in the Inclusive Framework reached agreement on a two-pillar solution to reform the international tax framework in response to the challenges of digitalisation. In Autumn Statement 2022, it was announced that the Multinational Top-up Tax and Domestic Top-up Tax would be introduced from accounting periods beginning on or after 31 December 2023 and the undertaxed profits rule from accounting periods beginning on or after 31 December 2024. Multinat

The UK 2024 Budget introduces significant tax changes, including increases in capital gains tax rates, reforms to carried interest taxation, a new residence-based non-dom regime, and measures to combat tax avoidance, with a focus on international compliance and transparency.

The Autumn Budget 2024 introduced key updates on employer NICs and the Corporate Tax Roadmap, aiming to create stability and streamline the tax landscape. Employer NICs will rise from 13.8% to 15% from April 2025, with reduced thresholds expanding liability but partially offset by an increased Employment Allowance. The Corporate Tax Roadmap maintains current corporate tax rates and reliefs while exploring simplifications in capital allowances, support for pre-development costs in renewables and