INTM414130 - Basic transfer pricing rules: Commissioners' sanction
S208 – 211 Determinations requiring Commissioners’ sanction
What has been amended, removed, or added in broad terms
The requirement for the Commissioners for HMRC to sanction transfer pricing determinations has been repealed.
This change has effect in relation to any transfer pricing determination made on or after the day on which Finance Act 2025-26 comes into force. Therefore, a determination made on 2 January 2026 will require a Commissioners’ sanction, even though the change will later remove that requirement.
Oversight of transfer pricing determinations will be provided through internal governance frameworks which were not in place when the legislative requirement for sanction was introduced and which have been operational for some time. This Business, Assets & International Transfer Pricing team will continue to be involved with transfer pricing determinations.
Previous rule, including links as appropriate to current INTM
The current guidance at INTM483090 will not be applicable from the date Finance Act 2025-26 comes into force.