01 June 2016

UK issues consultation on transfer pricing secondary adjustments

The UK's HM Revenue & Customs (HMRC) issued a consultation on May 26, on the potential introduction of a secondary adjustment rule into the UK's domestic transfer pricing legislation. Such a rule would be a new rule within the UK's transfer pricing legislation. Although the UK has not previously sought to introduce such a rule, the issue was highlighted as requiring a watching brief as far back as 1997, in the transfer pricing consultation document of that time.

A Tax Alert prepared by Ernst & Young UK, and attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2016-0950

Document ID: 2016-0950