UK HMRC has launched two public consultations on proposed changes in transfer pricing, permanent establishments, and diverted profits tax. Both consultations close at 11:59 pm on 7 July 2025. The first consultation concerns transfer pricing scope and documentation, which includes two proposals. The first proposal would amend the current exemption from transfer pricing for small and medium-sized enterprises (SMEs), bringing medium-sized enterprises into the scope of transfer pricing. This sits alongside wider reforms that will largely give an exemption from transfer pricing for transactions wholly within the UK (subject of the second consultation). The second proposal would introduce a requirement...