INTM489305 | The Unassessed Transfer Pricing Profits Practical Guidance: Introduction

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 Unassessed Transfer Pricing Profits rules (hereafter UTPP) were introduced in 2025 to replace the Diverted Profits Tax. They strengthen HMRC’s ability to challenge the use of contrived and artificial arrangements by multinational groups that seek to circumvent UK transfer pricing rules and thereby underreport profits attributable to UK economic activity.

The rules are an extension of the transfer pricing rules contained in TIOPA10/Part 4 (INTM410000) and form part of the UK’s corporation tax regime.

For more information on UTPP’s aims and its application see INTM489105.

References in the guidance are to the Taxation (International and Other Provisions) Act 2010 or TIOPA10 unless stated otherwise.