EMEA Dbriefs - Update on consultations on transfer pricing, permanent establishments and diverted profits tax 

Following the policy consultation in 2023, HMRC has published a technical consultation on changes to transfer pricing, permanent establishments, and diverted profits tax rules. A further consultation has also been published on potential changes, such as additional transfer pricing documentation and removal of the medium sized enterprise exemption. What will this mean for your organisation? We’ll discuss: 

• Changes to UK transfer pricing rules, including in relation to an exemption for some UK-UK transfer pricing and the transfer pricing rules on financial transactions 
  
• The potential introduction of an International Controlled Transactions Schedule (ICTS) reporting requirement 
• The abolition of diverted profits tax and replacement with the concept of ‘unassessed transfer pricing profits’ 
• Permanent establishment changes, including to the UK definition of a permanent establishment 

Keep up-to-date with this developing area.