What Will the UK Uncertain Tax Treatment Disclosure Rules Mean for Transfer Pricing?

New UK rules requiring disclosure of uncertain tax treatments are likely to have a significant impact on transfer pricing in the United Kingdom. Taxpayers within the scope of the rules will need to carry out careful review of their transfer pricing to determine whether there are uncertainties that must be notified. It is likely that HMRC’s internal guidance on transfer pricing will become far more important for taxpayers than has thus far generally been the case.