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Transfer pricing consultation

New UK transfer pricing rules could mean more reporting and fewer exemptions for mid-sized businesses. The government is consulting on proposals to tighten compliance and align with global standards. One key change would remove the transfer pricing exemption for medium-sized enterprises, keeping it only for small businesses. Another would introduce a new reporting requirement, the International Controlled Transactions Schedule (ICTS), to give HMRC more visibility over cross-border related-party transactions. These reforms aim to curb profit shifting, protect the UK tax base and simplify the rules for those who follow them.

Transfer pricing refers to how prices are set for transactions between companies that are part of the same group, especially when these transactions cross international borders. These prices must follow the “arm’s length principle,” meaning they should reflect what unrelated companies would charge under similar circumstances. This helps ensure that profits are taxed fairly where economic activity actually takes place.

The UK government is seeking feedback on two proposed changes to its transfer pricing rules. These proposals aim to protect the UK’s tax base from multinational enterprises (MNEs) shifting profits overseas, and to bring the UK in line with global best practices.

The first proposal suggests changing the current exemption from transfer pricing rules for small and medium-sized businesses (SMEs). In particular, it proposes removing the exemption for medium-sized enterprises but keeping it for small ones. The government also wants to update definitions and thresholds to make the rules clearer and easier to follow.

The second proposal would introduce a new reporting requirement called the International Controlled Transactions Schedule (ICTS). This would require MNEs to report cross-border related-party transactions to HMRC. The information would help HMRC better assess risk, reduce audit times, and support fairer, more efficient tax compliance whilst at the same time limiting extra burdens on businesses.

Higher penalties for MTD filers

Making Tax Digital for Income Tax will become mandatory in phases from April 2026. If you are self-employed or a landlord earning over £50,000 you need to start preparing to submit quarterly updates, keeping digital records and a new penalty system will apply.

Initially, MTD for IT will apply to businesses, self-employed individuals, and landlords with an annual income exceeding £50,000. From 6 April 2027, the rules will extend to those with an income between £30,000 and £50,000. A new system of penalties for late filing and late payment of tax will also be introduced.

From April 2028, sole traders and landlords with income over £20,000 will need to follow MTD rules. The government is also exploring ways to bring those earning under £20,000 within the MTD framework at a future date.

To help ensure taxpayers pay on time, HMRC increased the late payment penalties with effect from 1 April 2025. This applies to VAT-registered businesses as well as early adopters of Making Tax Digital for Income Tax.

The updated penalty rates are as follows:

  • 15 days late: increased from 2% to 3%
  • 30 days late: increased from 2% to 3%
  • From day 31 onwards: a 10% annual penalty now applies, up from 4%, with daily interest added from this point

Taxpayers that remain with self-assessment face a separate set of penalty rules.

Helping family or friends with their tax

Need to help a relative or friend with tax? HMRC’s Trusted Helper service makes it quick and easy to support someone online. Whether it is checking Income Tax, updating their personal details or reviewing taxable benefits like company cars or medical insurance, you can do it all with their permission. After registering as a trusted helper, your friend or family member simply needs to approve your access. You can help up to five people, but remember, they remain responsible for their own tax affairs.

This online option allows you to support someone, such as a friend or relative with key tax tasks, such as checking their Income Tax, updating their personal tax account or reviewing their taxable benefits (limited to company cars and medical insurance).

To get started, you must register online as a trusted helper. Once you have signed up, the person you are helping will need to log in and approve your request. If they cannot go online, you can call HMRC on their behalf, but they must be physically present with you during the call. HMRC will confirm their identity and their consent before proceeding. You will also need their National Insurance or tax reference number.

You can help up to five people using this service. While you can assist with their tax matters the person you are helping remains legally responsible for their own tax affairs. You must sign in using your Government Gateway details, and you may be asked to verify your identity using photo ID such as a passport or driving licence.

HMRC also offers this service in Welsh and provides additional support for those with disabilities or non-English speakers.

Applying for a National Insurance number

Working or claiming benefits in the UK? You may need to apply for a National Insurance number first. If you do not already have one, your NI number is essential for tracking tax, National Insurance contributions and accessing certain government services. While most UK residents receive their number at age 16, newcomers or those starting work later in life may need to apply. It takes around four weeks to process after proving your identity, but you can still start work or claim some benefits while you wait.

According to HMRC guidance, you can apply for a National Insurance number if you:

  • live in the UK,
  • have the legal right to work in the UK, and
  • are working, looking for work, or have a job offer.

You can still start work without an NI number, as long as you can prove your right to work in the UK. Similarly, you can apply for benefits or a student loan without an NI number, though you may be asked to provide one later if required.

Most teenagers living in the UK receive a letter shortly before their 16th birthday confirming their NI number. This letter is important and should be kept safe. Your NI number is unique and stays the same for life, even if your name, address or nationality changes. If you lose your NI number, you can find it on official documents like payslips, P60s or via your personal tax account.

New requirements for Overseas Entities

Overseas property owners must now report earlier ownership changes or risk penalties from 31 July 2025. Under new rules introduced by the Economic Crime and Corporate Transparency Act 2023, entities that registered on the UK’s Register of Overseas Entities must disclose any changes in beneficial ownership that occurred during their pre-registration period. This adds to the annual update requirements already in place and supports HMRC’s efforts to combat offshore tax non-compliance. Missing a deadline or failing to register can result in fines, and can make it impossible to sell or mortgage the property.

The Register of Overseas Entities came into force in the UK on 1 August 2022. The register is held by Companies House and requires overseas entities that own land or property in the UK to declare their beneficial owners and / or managing officers.

From 31 July 2025, overseas entities must report any beneficial ownership changes that occurred during the pre-registration period when filing an updated statement with Companies House. This is a new measure that was introduced under the Economic Crime and Corporate Transparency Act 2023.

The pre-registration period is different for every overseas entity. It’s between 28 February 2022 and either:

  • the end of the transition period (31 January 2023); and
  • the entity’s registration date, if it registered before 31 January 2023.

There is an annual filing requirement for the register of overseas entities. This means that registered entities must file an overseas entity update statement one year after the overseas entity was registered, and every year after that. This is required in order to inform Companies House of any changes, or to confirm that the information they hold is still correct.

Information on the register is available to HMRC and is used to help identify offshore tax non-compliance of:

  • overseas legal entities
  • overseas legal arrangements
  • beneficial owners (including settlors, beneficiaries etc).

There are financial penalties for entities that have failed to comply with the rules. As well as financial penalties, overseas entities which fail to register will find it difficult to sell, lease or raise charges over their land.