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Contents

Legislation

Finance Act 2026

Crossheading Other international matters

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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

Other international matters
Transfer pricing reform

Section 47 | Transfer pricing reform

From legislation.gov.uk

Schedule 6 makes provision about, and in connection with, transfer pricing.