Transfer pricing

FORTHCOMING CHANGE relating to UK transfer pricing legislation: At Autumn Budget 2024, and following a consultation on updating UK transfer pricing legislation (as well as legislation relating to the diverted profits tax and to permanent establishments), the government announced that it will be publishing a second-round consultation on reforms to modernise and simplify those rules in spring 2025. The government confirmed that this will include the potential removal of UK-to-UK transfer pricing to reduce the UK compliance burden. Consultations will also be launched in spring 2025 on further changes to the UK transfer pricing rules, including around lowering the existing thresholds for medium-sized businesses and introducing a new filing obligation for in-scope multinationals. The government will also be reviewing the transfer pricing treatment of cost contribution arrangements, where the costs and benefits of developing intellectual property are shared by group companies, and rectifying a current gap in the legislation relating to Advance Thin Capitalisation Agreements (for which legislation has been included in Finance Bill 2025). See News Analysis: Autumn Budget 2024—Tax analysis, Analysis—Reform of the UK’s international tax laws: a step closer (2024): Tax Journal, Issue 1652, 18 and

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

TAKE A FREE TRIAL

Latest Tax News

Finance Bill 2025 update: Public Bill Committee to begin in January

The Public Bill Committee is expected to begin scrutiny of the Finance Bill on 28 January 2025. Comments on the Bill are invited before then, and revised explanatory notes have been issued to cover the Government’s proposed Pillar 2 amendments.

FTT considers meaning of interest and decides that an element of redress payments constituted interest (NHS Mid & South Essex ICB and others v HMRC)

Tax analysis: In NHS Mid & South Essex ICB and others, the First-tier Tax Tribunal (FTT) decided that an element of the NHS continuing healthcare (CHC) redress payments constituted interest for the purposes of section 874 of the Income Tax Act 2007 (ITA 2007) and, furthermore, that the interest constituted yearly interest or was treated as yearly interest under ITA 2007, s 874(5A) since the interest was payable to individuals in respect of compensation.

Tax weekly highlights—19 December 2024

This week's edition of Tax weekly highlights includes: (1) the House of Commons committee debating (but not amending) clauses of the Finance Bill 2025, (2) the NICs Bill passing the House of Commons stages without amendment, and (3) the Spring Forecast to be published on 26 March 2025.

FTT applies carried-forward losses anti-avoidance rule (Blackfriars v HMRC)

Tax analysis: In Blackfriars Hotel (UK) Holdings Ltd, the First-tier Tax Tribunal (FTT) held that the anti-avoidance ‘loss refresh’ provisions of Part 14B of the Corporation Tax Act 2010 (CTA 2010) applied to disallow relief for pre-April 2017 carried forward loan relationship deficits against profits arising from tax arrangements entered into by the company.