INTM489110 | Unassessed Transfer Pricing Profits Conditions: Contents
From HM Revenue & Customs · International Manual
UTPP will apply to accounting periods beginning on or after 1 January 2026. For earlier accounting periods please use the diverted profits tax guidance at INTM489500
Contents9 entries
- INTM489115Unassessed Transfer Pricing Profits Conditions: Introduction to the Unassessed Transfer Pricing Profits Conditions
- INTM489120Unassessed Transfer Pricing Profits Conditions: Identifying Unassessed Transfer Pricing Profits
- INTM489125Unassessed Transfer Pricing Profits Conditions: Calculating Unassessed Transfer Pricing Profits
- INTM489130Unassessed Transfer Pricing Profits Conditions: The Effective Tax Mismatch Outcome (ETMO)
- INTM489135Unassessed Transfer Pricing Profits Conditions: ETMO Examples
- INTM489140Unassessed Transfer Pricing Profits Conditions: The Tax Design Condition (TDC)
- INTM489145Unassessed Transfer Pricing Profits Conditions: TDC Examples
- INTM489150Unassessed Transfer Pricing Profits Conditions: Exceptions
- INTM489155Unassessed Transfer Pricing Profits Conditions: Calculation of the UTPP Rate