In late 2025, the UK government introduced significant changes to the transfer pricing framework through the Finance (No. 2) Bill 2025–26. These reforms, which are expected to generally apply to accounting periods beginning...more
2/16/2026
/ Corporate Taxes ,
Cross-Border Transactions ,
Diverted Profits Tax ,
HMRC ,
International Tax Issues ,
New Legislation ,
OECD ,
Proposed Legislation ,
Reporting Requirements ,
Tax Avoidance ,
Tax Legislation ,
Tax Reform ,
Taxation ,
Transfer Pricing ,
UK
Overview -
As part of the 2025 Autumn Budget announcements, the UK Government confirmed that it will introduce legislation requiring certain multinational enterprises to file an annual International Controlled Transactions...more
12/12/2025
/ Cross-Border Transactions ,
HMRC ,
International Tax Issues ,
Multinationals ,
New Legislation ,
Proposed Legislation ,
Regulatory Requirements ,
Reporting Requirements ,
Taxation ,
Transfer Pricing ,
UK
In November 2025, HMRC updated its International Manual (INTM485120), setting out a more structured approach to how case teams and taxpayers should apply ranges in transfer pricing analyses....more