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ARTICLE · 27 JUNE 2025

UK-Perimeter Tax Rules Under The Spotlight

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Hogan Lovells Cadwalader

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On 28 April 2025, the UK government launched a consultation (the "Consultation") on proposed legislation to reform the UK's transfer pricing ("TP") and permanent establishment ("PE") rules, including changes to the investment manager exemption ("IME") and a repeal of the diverted profits tax ("DPT") regime.

United KingdomTax
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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On 28 April 2025, the UK government launched a consultation (the "Consultation") on proposed legislation to reform the UK's transfer pricing ("TP") and permanent establishment ("PE") rules, including changes to the investment manager exemption ("IME") and a repeal of the diverted profits tax ("DPT") regime.

These reforms build on a consultation initiated in 2023 (the "2023 Consultation") and are part of the UK government's approach to more closely align a number of these UK tax provisions to the 2017 version of the Organisation for Economic Co-operation and Development ("OECD") Model Tax Convention. The Consultation closes on 7 July 2025, with legislation expected to be included in the Finance Bill 2025–26 and to be effective from 1 January 2026.

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