Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.
On 16 January 2024 HMRC published a summary of the responses to the June 2023 consultation on potential reforms to the UK’s transfer pricing (TP) permanent establishments (PE) and diverted profits tax (DPT) rules. While the government’s comments on the responses are not conclusive in many areas they give a useful insight into policy thinking and the complexities still to be addressed before draft legislation is published.
The reforms aim to modernise the UK’s domestic rules by clarifying the application of TP PE and DPT while ensuring the outcomes they achieve remain consistent with the government’s policy intention international standards and the UK’s tax treaties. HMRC also see an opportunity to:
improve fairness: ensuring MNEs pay tax...
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Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.
On 16 January 2024 HMRC published a summary of the responses to the June 2023 consultation on potential reforms to the UK’s transfer pricing (TP) permanent establishments (PE) and diverted profits tax (DPT) rules. While the government’s comments on the responses are not conclusive in many areas they give a useful insight into policy thinking and the complexities still to be addressed before draft legislation is published.
The reforms aim to modernise the UK’s domestic rules by clarifying the application of TP PE and DPT while ensuring the outcomes they achieve remain consistent with the government’s policy intention international standards and the UK’s tax treaties. HMRC also see an opportunity to:
improve fairness: ensuring MNEs pay tax...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
