Closed consultation

Introduction of secondary adjustments into the UK’s domestic transfer pricing legislation

• From: HM Revenue & Customs
• Published: 26 May 2016

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Summary

Consultation on whether a secondary adjustment rule should be introduced into the UK’s transfer pricing legislation and how that rule would be designed.

This consultation ran from
4:30pm on 26 May 2016 to 11:45pm on 18 August 2016

Consultation description

Secondary adjustments represent an internationally recognised method to realign the economic benefit of a transaction with the arm’s length position.

The government is looking at the possible introduction of a rule into the UK’s domestic transfer pricing legislation as part of its commitment to ensure taxpayer compliance in this area and is seeking views on policy design and implementation issues.

Where a decision is made to introduce the rule, the government will consider the responses received in any subsequent drafting of the legislation, for inclusion in Finance Bill 2017.

Documents

Introduction of secondary adjustments into the UK’s domestic transfer pricing legislation

PDF, 282 KB, 18 pages

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Published 26 May 2016