Consultation outcome

UK law reform in transfer pricing, permanent establishment and Diverted Profits Tax

From:
HM Revenue & Customs
Published
19 June 2023
Last updated
16 January 2024 — See all updates
This consultation has concluded

Download the full outcome

Summary of responses

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Detail of outcome

The government invited views on the proposals to reform UK law in relation to transfer pricing, permanent establishment, and Diverted Profits Tax.  The consultation ran from 19 June to 14 August 2023.

HMRC received 42 written responses from representative bodies, professional advisers and individuals, and held 4 public meetings with over 300 people as part of the consultation.

The government has considered these responses and has today published the summary of responses document. The responses will be used to inform the further development of these proposals.  The government will hold a technical consultation on draft legislation in 2024.

Original consultation

Summary

The government is consulting on how to reform transfer pricing, permanent establishments and Diverted Profits Tax legislation to make it clearer and easier to use.

This consultation ran from
to

Consultation description

We welcome views on our proposals to reform the following UK laws:

  • transfer pricing: pricing transactions between related parties
  • permanent establishment: basis for taxing UK activities of non-UK resident companies
  • Diverted Profits Tax: anti-avoidance measure for countering arrangements designed to divert profits from the UK

We aim to clarify and modernise the legislation, and ensure it achieves its objectives, while developing simpler, legislation that is easier to understand, and supports growth by improving tax certainty.

This is of interest to:

  • multinational enterprises to whom these laws apply
  • advisory firms, representative bodies and legal firms

We will be holding a number of consultation events:

  • 27 June (registration closes 23 June)
  • 30 June (registration closes 26 June)
  • 6 July (registration closes 29 June)
  • 10 July (registration closes 29 June)

To register please complete this registration form before the closing date for your preferred event.

If you would like to submit any questions before the events please email them.  Please indicate in the subject heading which event your questions relate to.

Documents

Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax

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Published 19 June 2023
Last updated 16 January 2024 + show all updates

  1. Published outcome, including summary of responses.

  2. First published.