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Secondary adjustments represent an internationally recognised method to realign the economic benefit of a transaction with the arm’s length position.
The government is looking at the possible introduction of a rule into the UK’s domestic transfer pricing legislation as part of its commitment to ensure taxpayer compliance in this area and is seeking views on policy design and implementation issues.
Where a decision is made to introduce the rule, the government will consider the responses received in any subsequent drafting of the legislation, for inclusion in Finance Bill 2017.