Diverted profits tax

Stop Press: Clause 46 of, and Schedule 5 to, the Finance Bill 2026 (as introduced) abolishes the DPT regime and replaces it with the ‘unassessed transfer pricing profits’ (UTPP) rules, with effect for accounting periods beginning on or after 1 January 2026. HMRC has added a new chapter to the International Manual containing guidance on the UTPP rules at INTM489100. The DPT legislation will still have effect in respect of accounting periods beginning on or before 31 December 2025 so there are no apportionment rules for accounting periods which straddle 31 December 2025. UTPP applies where, broadly, (i) profits that ought to have been included in a company’s tax return by virtue of the UK’s transfer pricing rules were omitted, (ii) the omission secures a reduction in UK tax without a commensurate increase in tax in another jurisdiction (the effective tax mismatch outcome), and (iii) it is reasonable to assume that the arrangements were designed to achieve that UK tax reduction (the tax design condition). The UTPP rules sit within the corporation tax framework and only apply to companies within the charge to corporation tax (unlike

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Latest Tax News

Tax weekly highlights—15 January 2026

This week's edition of Tax weekly highlights includes: (1) News Analyses on the FTT’s decisions in Ripe Ltd and Littlewoods, (2) the UK’s double tax treaties with Andorra, Portugal and Romania coming into force, (3) News Analysis on the Court of Appeal’s decision in Sintra Global Inc and (4) the publication of the Scottish Budget.

FTT holds that taxpayer can recover input tax costs incurred in producing product-specific photos (Littlewoods Limited v HMRC)

Tax analysis: In Littlewoods Ltd v HMRC, the First-Tier Tax Tribunal (FTT) found in favour of the taxpayer against HMRC’s decision to refuse the taxpayer’s claims to recover input tax costs incurred in producing product-specific photographs (eg studio, modelling, props) used in catalogues and on its website.

Court of Appeal clarifies approach on burden of proof in penalty appeals (HMRC v Sintra Global Inc and another)

Tax analysis: In HMRC v Sintra Global Inc and another, the Court of Appeal considered whether the burden of proof falls on the taxpayer or HMRC in a penalty appeal where the taxpayer seeks to challenge the penalty on the basis that the underlying tax liability is wrong.

FTT finds that licence of client list and related data was an intangible fixed asset for corporation tax purposes (Ripe Ltd v HMRC)

Tax analysis: In Ripe Ltd v HMRC, the First-tier Tax Tribunal (FTT) allowed the taxpayer’s appeal against closure notices and assessments denying corporation tax deductions for the amortisation of a licence of a client list and related data on the basis that the licence was not an intangible fixed asset (IFA). Although the matters in question predate the successive rules that have applied to goodwill and customer-related IFAs (known as ‘relevant assets’) since 3 December 2014, the decision is a helpful illustration of some of the basic principles applicable to the taxation of IFAs.