On 26 May 2016, UK Treasury and HMRC launched a public consultation on whether to introduce secondary adjustment rules into domestic transfer pricing legislation. The potential rules would address the current issue that primary transfer pricing adjustments are only effective for tax purposes, while any cash benefit from non arm’s length pricing can accumulate in an overseas company. According to the consultation, the government's preferred secondary adjustment rule would treat the excess profits as a deemed loan from the potentially advantaged company. Such a deemed loan would have interest imputed upon it, which would then be treated as taxable income....