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Contents

Legislation
Finance Act 2026

Crossheading Other international matters

  • Section 46 Unassessed transfer pricing profits
  • Section 47 Transfer pricing reform
  • Section 48 International controlled transactions
  • Section 49 Permanent establishments
  • Section 50 Pillar two
  • Section 51 Controlled foreign companies: interest on reversal of state aid recovery
  • Section 52 Offshore income gains
  • Section 53 Offshore income gains: savings
  1. Other international matters
  2. Unassessed transfer pricing profits

Section 46 | Unassessed transfer pricing profits

From legislation.gov.uk

(1)Schedule 5 provides—

(a)for a power of His Majesty’s Revenue and Customs to assess “unassessed transfer pricing profits”,

(b)for those profits to be subject to a higher rate of corporation tax (rather than the main or any other rate), and

(c)for the abolition of diverted profits tax (which is superseded).

(2)The amendments made by that Schedule have effect in relation to accounting periods beginning on or after 1 January 2026.

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