Transfer pricing –— scope and documentation
Read the full outcome
Detail of outcome
The government has decided that small and medium-sized enterprises will continue to benefit from the existing exemption from transfer pricing.
Primary legislation relating to the International Controlled Transactions Schedule will be included in Finance Bill 2025 to 2026. A technical consultation on draft secondary legislation will be held in spring 2026. Changes are expected to take effect for accounting periods beginning on or after 1 January 2027.
Original consultation
Consultation description
This consultation concerns two transfer pricing related proposals, both aimed at protecting the UK tax base.
The first would amend the exemption for small and medium enterprises (SMEs) from transfer pricing.
The second would require multinationals to report information on cross-border related party transactions to HMRC.
Documents
Updates to this page
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Added summary of responses.
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First published.
Update history
2025-11-26 15:25
Added summary of responses.
2025-04-28 14:28
First published.