INTM489260 - The Unassessed Transfer Pricing Profits Process: Amendment of company tax return by the company
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
The UTPP rules target contrived arrangements by multinationals to avoid paying tax in the UK on profits that have been generated from economic activity here. A successful outcome is that the transfer pricing rules are applied correctly so that multinationals pay tax on their UK profits.
For most of the period for amendments, the company has an additional opportunity to amend its tax return so that it reflects the transfer pricing requirement relating to the UTPP. This opportunity can only be used to bring unassessed transfer profits into charge in the company’s tax return and not for anything else. Therefore, the normal time limits for amending a return do not apply. This extended time limit only applies to allow the company to bring all or part of the unassessed transfer pricing profits into charge and does not extend the normal time limit for any other amendments. There is no set form for an amendment under S217I.
Where a company amends its tax return, HMRC will review the assessment and reduce or withdraw it accordingly.
An amendment under S217I(2) may not be made in the last 21 days of the period for amendments, unless the period for amendments ends by agreement in accordance with S217(4). This is to allow HMRC sufficient time to conduct a review and take any appropriate action.
It should be noted that FA98/Sch18/Para31 with regards to amendments not taking effect during an enquiry does not apply to amendments made under S217I(2).