Reform of transfer pricing, permanent establishment and Diverted Profits Tax
Read the full outcome
Detail of outcome
The government has decided to move forward with the reform of UK law in relation to transfer pricing, permanent establishment, and Diverted Profits Tax.
Primary legislation relating to these reforms will be included in Finance Bill 2025 to 2026. In general, these changes will take effect for chargeable periods beginning on or after 1 January 2026.
Original consultation
Consultation description
This is a technical consultation on draft legislation for the reform of 3 areas of the UK’s international tax rules:
- transfer pricing
- permanent establishment
- Diverted Profits Tax
It follows a policy consultation on these issues in summer 2023.
On this page, you can read:
- consultation document: Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax
- Statement of Practice 1 (2001): treatment of investment managers and their overseas clients
- draft legislation: permanent establishment
- draft explanatory notes: permanent establishment
- draft legislation: transfer pricing
- draft explanatory notes: transfer pricing
- draft legislation: unassessed transfer pricing profits
- draft explanatory notes: unassessed transfer pricing profits
You can also read a tax information and impact note.note.
Documents
Updates to this page
-
Published consultation outcome, including summary of responses.
-
First published.
Update history
2025-11-26 15:25
Published consultation outcome, including summary of responses.
2025-04-28 14:28
First published.