INTM489255 - The Unassessed Transfer Pricing Profits Process: Period for Amendments
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
TIOPA10/S217I
Following the assessment there is a 15-month period for amendments beginning the day after the day on which the designated officer assesses the company’s unassessed transfer pricing profits.
This is an opportunity for HMRC and the company to engage in more detailed discussions and for HMRC to understand the facts, review any supporting evidence and refine our view of the unassessed transfer pricing profits.
HMRC encourages companies subject to UTPP assessments to engage during the period for amendments, and to provide any relevant information, documents or analysis. Companies can also ask HMRC to provide further information on the application of UTPP to their particular arrangements. For more information on engagement between companies and HMRC in relation to UTPP see INTM489300.
The designated officer and the company may agree, in writing, to terminate the period for amendments early. The period ends when the agreement is made. HMRC will generally accept an application for early termination of the period for amendments.