United Kingdom: Transfer Pricing

Since taking office, President Trump has imposed significant tariffs on a wide range of goods imported into the US. These actions sharply reverse historic US trade policy...

As the global economy enters a new phase of regulatory transformation, tax compliance has become a defining challenge for businesses across Europe

In our recent experience, disputes over the transfer pricing of "high-value" intragroup services are increasingly becoming a key area of focus for HMRC.

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

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.

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.

HMRC yesterday launched a consultation on a package of reforms to three important parts of the UK tax code. The areas being reviewed, which all have an international element...

Macfarlanes has responded to the Government consultation to reform transfer pricing, permanent establishments and the Diverted Profits Tax.

As part of the proposed reforms announced on Tax Administration and Maintenance Day 2023, the UK government is consulting on potential changes to the UK legislation on transfer pricing...