In 2004, the UK government reacted to the Lankhorst case by replacing the old thin-capitalization provisions with new transfer pricing legislation and by applying all transfer pricing legislation within the United Kingdom as well as on cross-border transactions. The 2005 Finance Bill was delivered on 24 March, weighing in at 364 pages. Though much of the transfer pricing legislation may have been aimed at private equity transactions, it will have an impact far more wide than that. Also, the Revenue has decided to limit the corresponding adjustments available within the United Kingdom, when a transfer pricing adjustment in one company would otherwise be matched in the counter-party. In this article, the authors describe the background of these proposed changes and examine their intended effect.