INTM489210 - The Unassessed Transfer Pricing Profits Process: Example Timeline
UTPP will apply to accounting periods beginning on or after 1 January 2026. This guidance will be updated with detailed examples by 1 January 2026. For earlier accounting periods please use the diverted profits tax guidance at INTM489500
This is an illustrative timeline for a company with a 12-month accounting period ended 31 December 2026. The company’s self-assessment was delivered on time and the other party to the provision is not a transparent entity:
Submission -The company’s self-assessment submission deadline is 12 months after the accounting period, so 31 December 2027.
Preliminary Notice – The preliminary notice must be issued by HMRC within 4 years of the end of the accounting period, so 31 December 2030.
Representations - If the preliminary notice was issued on 1 June 2028 then the company has 30 days to make representations beginning with the day the notice is issued, so until the end of 30 June 2028.
Assessment - HMRC has 60 days from the issue of the preliminary notice to consider any representations and decide whether to make an assessment, so the end of 30 July 2028. The assessment is made on 28 July 2028.
Period for amendments - The period for amendments is 15 months beginning with the day after the date HMRC assesses the UTPP, starts on 29 July 2028 and the last day is 28 October 2029.
HMRC can review the assessment and increase it within the first 14 months of the period for amendments, so until 28 September 2029. HMRC can reduce or withdraw the assessment until the end of the period for amendments.
The company can amend its tax return to partially or wholly bring the unassessed transfer pricing profits into account until the last 21 days of the period for amendments, so until the end of 7 October 2029.
UTPP Charge Finalises – The last day of the period for amendments is 28 October 2029, the company has 30 days from the end of the period to appeal or any charge becomes final, so until 28 November 2029.