Episode 115: Ready or Not? Navigating the UK’s next TP chapter

Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing Practice) is joined by James Andrews (PwC UK Tax Partner and UK Transfer Pricing Leader), Sonia Watson (Transfer Pricing Partner at PwC UK), and Sara Harris (Director at PwC UK and former HMRC TP Policy Team Leader). Kristina and her guests discuss the UK government’s proposed reforms to transfer pricing, permanent establishments, and the Diverted Profits Tax. They outline HMRC’s expanding audit activity, the new UK transfer pricing (TP) documentation rules effective from April 2023, and the critical implications for penalty exposure and statute of limitations. The conversation covers two current consultations: one aimed at reforming the rules governing transfer pricing, permanent establishment, and Diverted Profits Tax, including the removal of UK-UK TP requirements and changes to financial transactions; and a second introducing the International Controlled Transactions Schedule reporting requirement and narrowing SME exemptions. The episode closes with advice on documentation best practices, evidence expectations, and why governance, not just documentation, defines TP risk posture today. Support the show

You can listen to Episode 115: Ready or Not? Navigating the UK’s next TP chapter online on Radio and Podcast. Open the player on this page to stream the available audio.

Episode 115: Ready or Not? Navigating the UK’s next TP chapter is an episode from TP Talks - PwC's Global Transfer Pricing podcast by PwC.

This episode is 33:46 long.

This episode was published on Jul 31, 2025.

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