INTM489250 | The Unassessed Transfer Pricing Profits Process: Designated Officer

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

The decision to issue a preliminary notice, to assess a company’s unassessed transfer pricing profits, and to amend or withdraw an assessment can only be made by a designated officer.

The role of the designated officer and associated governance process is an important safeguard for companies within the UTPP rules, because it ensures that key decisions are made by a senior and experienced international tax specialist who is independent from the case team. The designated officer should consider the facts and circumstances of each case and the application of the legislation for each accounting period.

217T defines a designated officer as an officer of Revenue and Customs who has been designated by the Commissioners for His Majesty's Revenue and Customs for the purposes of Part 4A TIOPA 2010.

The designated officer is supported by the Diverted Profits Advisory Group (DAG). This is a panel with a mixture of UTPP compliance and policy experience. The panel reviews submissions from compliance case teams and make a recommendation to the designated officer drawing upon their experience which the designated officer can then use to inform their decision. Further information on the governance process is in INTM489340.