Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.
On 19 June 2023 the government published a consultation document entitled Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax which includes an extensive package of proposals that touch most areas of the UK’s transfer pricing permanent establishment (PE) and diverted profits tax (DPT) legislation. The consultation is the most significant review of the UK’s core transfer pricing legislation since the early 2000s. In this article we review the proposals and consider how they will impact businesses if they are pursued.
Transfer pricing
The section of the consultation document that deals with transfer pricing covers three areas.
Framework
The consultation advances several proposals aimed at simplifying and clarifying the...
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Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.
On 19 June 2023 the government published a consultation document entitled Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax which includes an extensive package of proposals that touch most areas of the UK’s transfer pricing permanent establishment (PE) and diverted profits tax (DPT) legislation. The consultation is the most significant review of the UK’s core transfer pricing legislation since the early 2000s. In this article we review the proposals and consider how they will impact businesses if they are pursued.
Transfer pricing
The section of the consultation document that deals with transfer pricing covers three areas.
Framework
The consultation advances several proposals aimed at simplifying and clarifying the...
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:
