Precedent transfer An adaptable word version of the precedent form TR2 can be downloaded, saved or printed from this link: . Drafting notes to precedent transfer General This Precedent transfer is for use on the transfer of the whole of a registered or unregistered estate in land by a mortgagee exercising their statutory power of sale under section 101 of the Law of Property Act 1925 (LPA 1925). The form of the transfer is in HM Land Registry prescribed form TR2. If the transfer is a transfer of part of the land in a registered title, form TP2 must be used. Acting for a mortgagee on the exercise of their power of sale A mortgagee who wishes to exercise their power of sale must check that the power of sale: • exists • has arisen, and • has become exercisable The mortgagee’s power of sale becomes exercisable if one of the conditions set out in LPA 1925, s 103 is met. The conditions are: • notice requiring payment of the mortgage has been served on the mortgagor (or one of them) and default has

Precedent transfer The invariable modern practice is for exchanges to be effected by separate transfers, each containing the usual title guarantees ordinarily given by sellers. There is no restriction on the nature or value of the properties exchanged. A freehold interest can validly be exchanged for a leasehold interest (IRC v Littlewoods Mail Order Stores [1962] 2 All ER 279, HL) and any necessary payment can be included to achieve equality of exchange. An adaptable Word version of the precedent form TR1 can be downloaded, saved or printed from the link below: Drafting notes to precedent transfer Panel 1—Title numbers If there are a number of properties, each title number should be listed alphanumerically and may be numbered starting with one, with each property then being listed in the same order as the title numbers and correspondingly numbered. Panel 2—Property description The optional wording is for use where the Property is unregistered. It is not usually necessary to refer to a plan in a transfer of the whole of unregistered land. It is normally sufficient to refer to the

A payment made from one pension scheme to another pension scheme, or to an insurance company to purchase a buy-out policy, in lieu of benefits which have accrued to the member under the scheme.

A regime which requires a business enterprise to calculate its taxable profits arising from transactions with related persons by reference to an arm's length result.

Scope of this Practice Note Transfer pricing relates to the pricing of goods, services, funds and assets provided within a group and between connected parties. As the prices are set with the mutual agreement of the parties, they are not subject to the normal market pressures that establish prices for similar transactions between third parties. Therefore, one of the parties may receive a tax advantage as a result of the provision not being at arm’s length, eg where that party’s taxable profits have been reduced or its tax losses increased. The transfer pricing rules require that, in such circumstances, the profits and losses of the potentially tax advantaged person must be adjusted for tax purposes by applying the amount of taxable profit that would have arisen if the transaction had been carried out by unconnected parties on an arm’s length basis. This Practice Note provides an overview of how UK transfer pricing rules apply to the intra-group provision of employee share incentive plans, in relation to both those plans that operate over newly issued shares and those

Rules that require that transactions between connected parties are recognised for tax purposes by applying the amount of profit or loss that would have arisen if the same transaction had been carried out by unconnected parties. This is referred to as the 'arm's length principle'.

FORTHCOMING CHANGE relating to the International Controlled Transactions Schedule: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) were published for technical consultation on 16 June 2026, along with a draft ICTS notice and template illustrating the information that would need to be filed. The consultation closed on 31 July 2026. FORTHCOMING CHANGE relating to OECD Transfer Pricing Guidelines: On 1 June 2026, the OECD opened a public consultation on proposed revisions to Chapter VII of its Transfer Pricing Guidelines, covering special considerations for intra-group services. The OECD stated that the revisions are not intended to change the general principles underlying the transfer pricing analysis of intra-group services; rather, their primary objective is to ensure alignment

FORTHCOMING CHANGE relating to UK transfer pricing: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) were published for technical consultation on 16 June 2026, along with a draft ICTS notice and template illustrating the information that would need to be filed. The consultation closed on 31 July 2026. This Practice Note looks at what happens when a person’s taxable profits or losses are adjusted as a result of the UK’s transfer pricing rules applying to a particular transaction. It looks at the potential for the other party to the transaction to claim a compensating tax adjustment under the UK legislation or under the compensating adjustment mechanism provided by certain double tax treaties. It also looks at

This Practice Note explains what happens when a person’s taxable profits or losses are adjusted as a result of the UK’s transfer pricing rules applying to a particular transaction. It looks at the potential for the other party to the transaction to claim a compensating tax adjustment under the UK legislation or under the compensating adjustment mechanism provided by certain double tax treaties. It also looks at the treatment of balancing payments and the extension of the ability to claim a compensating adjustment to financial guarantors in certain circumstances. This Practice Note looks at the UK’s transfer pricing legislation prior to the reforms introduced by Finance Act 2026. Finance Act 2026 introduced a number of reforms to the UK’s transfer pricing rules, most of which took effect for accounting periods beginning on or after 1 January 2026, however in the case of loans already existing on 1 January 2026 the changes were subject to transitional commencement rules. For the transfer pricing rules that apply following the Finance Act 2026 changes and details of those

STOP PRESS relating to UK transfer pricing legislation: Finance Act 2026 introduced wide-ranging reforms to the UK’s transfer pricing legislation. These included removing UK-to-UK transfer pricing (subject to exclusions, in order to prevent opportunities for tax arbitrage), amending the participation condition, clarifying that the OECD Model Tax Convention and OECD Transfer Pricing Guidelines are interpretative aids, and make several changes to the provisions governing financial transactions to better align the UK rules with the OECD Transfer Pricing Guidelines. Most of the changes took effect for accounting periods beginning on or after 1 January 2026, although the amendments relating to financing transactions have their own commencement and transitional rules. FORTHCOMING CHANGE relating to cross-border related party transactions: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International

FORTHCOMING CHANGE relating to UK transfer pricing: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) were published for technical consultation on 16 June 2026, along with a draft ICTS notice and template illustrating the information that would need to be filed. The consultation closes on 31 July 2026. Groups expecting to be in scope would do well to start the mapping exercise early—putting related-party transactions into the prescribed categories tends to expose pricing positions that are better looked at before they are reported. FORTHCOMING CHANGE relating to OECD Transfer Pricing Guidelines: On 1 June 2026, the OECD opened a public consultation on proposed revisions to Chapter VII of its Transfer Pricing

FORTHCOMING CHANGE relating to UK transfer pricing: At Budget 2025, the government announced that it would be proceeding with a requirement for in-scope multinationals to report information annually on cross-border related party transactions for accounting periods beginning on or after 1 January 2027. A consultation on this measure had run from April to July 2025. (See News Analysis: Budget 2025—Tax analysis—International.) The technical regulations for this new ‘International Controlled Transactions Schedule’ (ICTS) were published for technical consultation on 16 June 2026, along with a draft ICTS notice and template illustrating the information that would need to be filed. The consultation closed on 31 July 2026. This Practice Note looks at the UK’s transfer pricing rules applicable to loans, guarantees and other financial arrangements following the changes made by Finance Act 2026 (FA 2026)—ie it covers the rules applicable to accounting periods beginning on or after 1 January 2026, subject to certain transitional rules for existing loans (see below). For the transfer pricing position that applied prior