UK Eyes Bringing Medium-Sized Firms Into Transfer Pricing Rules

April 28, 2025, 7:43 PM UTC

The UK proposed wide-ranging reforms to its transfer pricing law Monday, including requiring medium-sized businesses for the first time to comply with the law, and multinationals to submit documentation on cross-border transactions on an annual basis.

His Majesty’s Revenue and Customs is proposing to remove exemptions medium-sized enterprises have from transfer pricing norms to plug a gap in protecting the UK tax base that “gives rise to a significant risk of cross-border profit diversion,” a consultation document said.

Medium-sized enterprises are those with staff of up to 250 and either an annual turnover of 50 million euros ...

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