INTM489330 - The Unassessed Transfer Pricing Profits Practical Guidance: Internal Advice and Support
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
An internal advice and support network ensures that CCMs and case workers have a clear route to comprehensive guidance at all stages in dealing with UTPP. This supports their engagement with customers and ensures that UTPP is administered consistently and effectively. The network includes:
LB International Tax Specialists and MSB Profit Diversion Technical Co-ordinators - they provide case workers and CCMs with leadership on unassessed transfer pricing profit issues and technical support on the application of UTPP throughout both the risk assessment and working of the case. They can also provide case workers and CCMs with advice and support in relation to other international risks such as transfer pricing or permanent establishments. They liaise with the Diverted Profits Unit and, when necessary, with technical and policy specialists in Business, Assets and International (BAI) as well as engaging with customers.
Diverted Profits Unit - a team of operational specialists based in Large Business. They provide advice to case workers, LB International Tax Specialists and MSB Profit Diversion Technical Co-ordinators on the application of the UTPP legislation. They also oversee the process of issuing UTPP preliminary notices and making assessments, supporting the designated HMRC officer and co-ordinating the governance process (further detail on governance is in INTM489340).
DPT Policy Team – The DPT Policy team sit within BAI’s Transfer Pricing Team. CCMs and case workers can approach the DPT Policy Team for advice on specific areas of the legislation. This should usually be done through submitting a BAI Formal Submission Form.