Key points
- The UK government has published a consultation on simplifying and updating the legislation in relation to diverted profits tax transfer pricing and permanent establishments.
- A key theme of the consultation is to achieve a closer alignment of the UK legislation with OECD terminology.
- A number of the proposals appear positive and the government’s overarching objectives of clarity and consistency with international standards are sensible.
- Stakeholders should review the proposals in detail and provide carefully considered responses.
As part of the tax administration and maintenance day on 27 April 2023 the government announced that it would publish in May a consultation on simplifying and updating the legislation in relation to diverted profits tax (DPT) transfer pricing (TP) and permanent establishments (PE).
In making this announcement the government stated that the purpose of the consultation would be to ‘ensure that their application is clear...