UK SME Exemption, India PE Ruling : Transfer Pricing Report

Nov. 28, 2025, 10:04 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Kathy Larsen, standing in while Caleb Harshberger is away. We miss him a lot, but we’re all over activity in the UK, where HMRC said it won’t pull medium-sized companies into its transfer pricing net after all, and in India, where the Supreme Court took a stand on permanent establishment.

The UK government will drop its plan to bring medium-sized businesses under the country’s transfer pricing rules, our Somesh Jha reports.

With the government’s budget release Wednesday, HMRC said it would go ahead with some of the change it proposed ...

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