United Kingdom: Transfer Pricing

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Tax law and international tax law thought leadership, articles, podcasts, videos and webinars from expert sources across the legal world. Explore insights covering topics such as capital gains tax, corporate tax, income tax, inheritance tax, national insurance, property taxes, sales taxes, VAT, GST, tax authorities, transfer pricing and withholding tax.

Happy New Tax Year 2026/27!

Both dates mark the entering into force of a range of new legislative provisions. Most of these provisions are contained in the Finance Act 2026 (which received Royal Assent on 18 March 2026).

United Kingdom Tax

TS

Travers Smith LLP

Mutual Agreement Procedures (MAP): OECD Publishes New Manual For Effective International Tax Disputes

On 2 February 2026, the Organisation for Economic Co-operation and Development (OECD) published an updated edition of the Manual on Effective Mutual Agreement Procedures (MEMAP).

United Kingdom Tax

M

Macfarlanes LLP

Tax Disputes Newsletter - January 2026

Last January we wrote about how everything felt a bit "déjà vu" – with Trump about to enter the White House for a second term, and an optimistic Labour government still riding off a landslide victory

United Kingdom Tax

M

Macfarlanes LLP

Countdown To The International Controlled Transactions Schedule – How UK Businesses Can Prepare For New Transfer Pricing Reporting Requirements

With the rise and rapid adoption of advanced data analytics and AI tools, transfer pricing compliance and risk assessment is quickly shifting from being a documentation-focused process to a near real time, data-driven one.

United Kingdom Tax

M

Macfarlanes LLP

Budget 2025 – Our Briefing On The Principal Measures

United Kingdom Tax

KL

Herbert Smith Freehills Kramer LLP

The Autumn Budget 2025: Business Tax Perspective

United Kingdom Tax

M

Macfarlanes LLP

Opportunity Knots – Budget 2025

United Kingdom Tax

LS

Lewis Silkin

Transfer Pricing: New HMRC Guidance Raises The Bar For Benchmarking Studies

United Kingdom Tax

M

Macfarlanes LLP

UK Transfer Pricing Documentation Rules: What's Changing?

United Kingdom Tax

GGI Global Alliance

Trump Tariffs: The UK Response

Worldwide International

M

Macfarlanes LLP

Navigating Tax Compliance: How Italian Businesses Can Stay Ahead Of Global Change

United Kingdom Tax

IG

IR Global

Transfer Pricing: Can HMRC Raise More Corporate Tax From "High-value" Intragroup Services?

United Kingdom Tax

M

Macfarlanes LLP

Tax - Corporate: Insights For In-house Counsel - Autumn 2025

United Kingdom Tax

TS

Travers Smith LLP

United Kingdom Tax

WG

Weil, Gotshal & Manges LLP

Tech Predictions For 2026: The Year Ahead Promises To Be Anything But Predictable

United Kingdom Technology

LS

Lewis Silkin

Episode 18: Massive Attack Helped Me Build A Multi-million Pound Business (Video)

United Kingdom Commercial

AM

Alvarez & Marsal

The European Commission's Digital Package: What It Means For Cybersecurity Compliance

European Union Technology

N

NAVEX

The Business Behind Sport: What Makes Sports Sponsorship (Podcast)

United Kingdom Commercial

AC

Ankura Consulting Group LLC

Stopping Counterfeiters In Their Tracks For Equip Outdoor Technologies UK Ltd (Video)

United Kingdom IP

GW

Gowling WLG

Proposed Reform Of The UK Investment Manager Exemption (IME)

On 28 April 2025, the UK government began a consultation on new draft legislation and HMRC guidance...

United Kingdom Tax

SR

McDermott Will & Schulte

Transfer Pricing: The Government's Latest Compliance Proposals

On 28 April the Government made an important set of transfer pricing policy announcements...

United Kingdom Tax

M

Macfarlanes LLP

UK Tax Round Up

Welcome to April's edition of our UK Tax Round Up. While this month has been quiet on the case law front, there have been a number of HMRC announcements and updates to prior published...

United Kingdom Tax

PR

Proskauer Rose LLP

Tariffs And Tax – A Different Perspective

Given that the threat of tariffs has now become a reality there's no shortage of commentary on this subject. This note puts to one side the geopolitics of the tariff rates and instead focuses on the interaction of tariffs...

United Kingdom Tax

M

Macfarlanes LLP

Permanent Establishment And The Investment Management Exemption: Proposed Reforms

United Kingdom Tax

M

Macfarlanes LLP

UK Transfer Pricing: What To Look Out For In 2025

United Kingdom Tax

M

Macfarlanes LLP

Autumn Budget 2024: Corporate And Related Tax Implications

United Kingdom Tax

SW

Spencer West

Autumn Budget 2024 - International

United Kingdom Tax

TS

Travers Smith LLP

The UK Government's Autumn Budget 2024

United Kingdom Tax

CW

Cadwalader, Wickersham & Taft LLP

Autumn Budget 2024 - Business Taxes

United Kingdom Tax

TS

Travers Smith LLP

How To Avoid Common Pitfalls In Transfer Pricing

United Kingdom Tax

M

Macfarlanes LLP

Tax Disputes Newsletter - September 2024

United Kingdom Tax

M

Macfarlanes LLP

UK Tax Round Up

United Kingdom Tax

PR

Proskauer Rose LLP

UK Tax Round Up - April 2024

United Kingdom Tax

PR

Proskauer Rose LLP

How To Avoid Common Pitfalls In Transfer Pricing

HMRC has issued detailed transfer pricing compliance guidelines, emphasizing roles for "UK risk leads" and "transfer pricing specialists" to manage compliance, avoid high-risk approaches, and ensure thorough documentation and functional analysis, reducing audit uncertainties for UK businesses.

United Kingdom Tax

M

Macfarlanes LLP

Tax Disputes Newsletter - September 2024

Labour's first budget introduces reforms targeting VAT exemptions, non-dom regimes, and tax avoidance, while courts scrutinize tax motive cases, impacting intra-group lending and unallowable purpose rules.

United Kingdom Tax

M

Macfarlanes LLP

UK Tax Round Up

Welcome to May's edition of the UK Tax Round Up. This month has seen three interesting tribunal decisions on the unallowable purpose test applied to intragroup

United Kingdom Tax

PR

Proskauer Rose LLP

UK Tax Round Up - April 2024

Welcome to April's edition of our UK Tax Round Up.

United Kingdom Tax

PR

Proskauer Rose LLP

Transfer Pricing – The Foundations For A Sustainable Tax Policy In The Middle East

AM

Alvarez & Marsal

Proposed Reforms Of The UK's Transfer Pricing, Permanent Establishment And Diverted Profits Tax (DPT) Rules

The proposed reforms to the UK's transfer pricing, permanent establishment and the diverted profits tax ("DPT") legislation will more closely align the UK's rules with international standards...

United Kingdom Tax

PB

Price Bailey

UK Tax Round Up

Welcome to January's edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses...

United Kingdom Tax

PR

Proskauer Rose LLP

Your Essential Guide To Investing In The UK

Whether you are moving to the UK, investing in the UK, or looking to grow your business internationally, we know that it can be daunting.

United Kingdom Tax

GE

Gerald Edelman

Reforming Transfer Pricing, Permanent Establishments And Diverted Profits Tax – Government Response

Following a consultation over the summer of 2023 the Government has considered the responses it received to its proposals to reform transfer pricing...

United Kingdom Tax

M

Macfarlanes LLP

What Legal Developments Can Businesses In The UK Expect In 2024?

United Kingdom Strategy

OC

Osborne Clarke

HMRC Believes US Companies Underpaid £5.6bn In UK Tax, Up 14% In A Year

UH

UHY Hacker Young LLP

UHY Global Transfer Pricing Guide 2023

United Kingdom Tax

UH

UHY Hacker Young LLP

The Special Relationship: The Opportunity For Businesses Expanding To The US

Worldwide Commercial

B

Buzzacott

Cost Plus And Open Book Pricing: What To Watch Out For

United Kingdom Tax

TS

Travers Smith LLP

HMRC Consults On Reforms To Transfer Pricing, Permanent Establishment And Diverted Profits Tax Rules

United Kingdom Tax

TS

Travers Smith LLP

Response To Proposals To Reform Transfer Pricing, Permanent Establishments And DPT

United Kingdom Tax

M

Macfarlanes LLP

Reviewing The HMRC Consultation On Transfer Pricing Reform

United Kingdom Tax

M

Macfarlanes LLP

UK Transfer Pricing Documentation Changes From 1 April 2023

United Kingdom Tax

UH

UHY Hacker Young LLP

UK Tax Round Up

United Kingdom Tax

PR

Proskauer Rose LLP

View On The Spring Budget 2023

United Kingdom Tax

AM

Alvarez & Marsal

The Tax Break Podcast | Implications Of The Blackrock Case (Podcast)

United Kingdom Tax

OC

Osborne Clarke

UK Tax Round Up

United Kingdom Tax

PR

Proskauer Rose LLP

Tax-Related Measures In The Autumn Statement 2022

European Union Tax

JH

Joseph Hage Aaronson

Update On IRS Enforcement Efforts

United Kingdom Tax

MW

McDermott Will & Emery

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Latest Videos

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Webinar: Tackling Transfer Pricing Litigation For Multinationals Operating In Europe

NE

NERA Economic Consulting

Deloitte Transfer Pricing Digital DoX (Video Content)

D

Deloitte

Deloitte CbC Digital Exchange (Video Content)

D

Deloitte

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