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UK Summary of Responses to Proposed Transfer Pricing, Permanent Establishment, and Diverted Profits Tax Reforms

23 January 2024

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Proposed Changes

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United Kingdom

UK HMRC has published the summary of responses to its public consultation on the reform of UK law in relation to transfer pricing, permanent establishment, and diverted profits tax (previous coverage). --- Executive Summary The government is developing a package of reforms to 3 elements of UK international tax legislation: transfer pricing, permanent establishments, and Diverted Profits Tax. The aims of these reforms are to modernise and simplify these rules, in order to improve tax certainty and alignment with treaties. Which rules are being considered? Transfer pricing rules: The transfer pricing rules require that, in calculating profits subject to Corporation...