United Kingdom: Transfer Pricing

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Article
UK Tax Authority Will Transform Transfer Pricing Risk Assessment
The UK's new International Controlled Transactions Schedule (ICTS) will fundamentally transform how HMRC assesses transfer pricing risks, shifting from documentation-focused reviews to data-driven analysis powered by AI and advanced analytics. With mandatory filing beginning January 1, 2027, multinational enterprises must prepare to provide detailed, standardized information about cross-border related party transactions, facing unprecedented scrutiny and visibility of their transfer pricing arrangements.
United Kingdom Tax
M
Macfarlanes LLP
Article
How Reforms To Global Minimum Tax Standards Could Impact Dealmaking
The OECD's side-by-side package introduces new safe harbors for multinational groups under Pillar Two's global minimum tax regime, responding to U.S. concerns about undertaxed profits rules and existing tax credits. These reforms create significant implications for M&A transactions, particularly affecting due diligence processes, target pricing certainty, and contractual protections for deals involving U.S. acquirers and joint venture structures with mixed investor bases.
United Kingdom Tax
AO
A&O Shearman
Article
European Commission's Tax Simplification Package And The Future Of The Unshell Substance Tests
The European Commission has adopted a tax simplification package that abolishes withholding taxes on cross-border payments and modernises key direct tax directives. For private capital managers, the most significant development may be the formal withdrawal of the controversial Unshell Directive, though substance requirements remain on the regulatory agenda in a different form.
United Kingdom Tax
M
Macfarlanes LLP
Article
Beyond Cost-Plus: What The OECD's New Approach To Intra-Group Services Means For UK Taxpayers
The OECD has proposed significant revisions to its transfer pricing guidance on intra-group services, expanding practical examples and emphasizing the need for robust documentation to evidence service provision and benefits. While core principles remain unchanged, the updates create potential tensions with HMRC's more prescriptive approach to high-value services, particularly around pricing methodologies and the treatment of shareholder activities.
United Kingdom Tax
M
Macfarlanes LLP
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