Open consultation

Reform of transfer pricing, permanent establishment and Diverted Profits Tax

From:
HM Revenue & Customs
Published
28 April 2025

Summary

We welcome views on these proposals to reform the UK’s transfer pricing, permanent establishment and Diverted Profits Tax rules.

This consultation closes at

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.

Documents

Reform of UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax

HTML

Statement of Practice 1 (2001): treatment of investment managers and their overseas clients

HTML

Draft legislation: permanent establishment

PDF, 363 KB, 10 pages

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft explanatory notes: permanent establishment

ODT, 18.5 KB

This file is in an OpenDocument format

Draft legislation: transfer pricing

PDF, 956 KB, 30 pages

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft explanatory notes: transfer pricing

ODT, 27.7 KB

This file is in an OpenDocument format

Draft legislation: unassessed transfer pricing profits

PDF, 457 KB, 15 pages

This file may not be suitable for users of assistive technology.

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft explanatory notes: unassessed transfer pricing profits

ODT, 19.8 KB

This file is in an OpenDocument format

Ways to respond

Email to:

dpt-tp-pe-reform@hmrc.gov.uk

Updates to this page

Published 28 April 2025

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