From www.icaew.com: [UK context] The UK government plans to reform international tax rules, focusing on narrowing the scope of UK-UK transfer pricing rules and replacing the diverted profits tax with a new corporation tax provision for unassessed transfer pricing profits.

Key changes include introducing a general exemption for transfer pricing between UK companies, simplifying intangible asset valuation, and aligning definitions of permanent establishment with international standards.

These proposals are part of a broader consultation running until July 7, 2025, inviting feedback on the outlined reforms.