Policy paper

New transfer pricing documentation requirements for UK businesses

This measure sets out new transfer pricing documentation requirements for the largest UK businesses to retain, and produce upon request, a master file, local file and summary audit trail.

• From: HM Revenue & Customs
• Published: 20 July 2022

Documents

Transfer pricing documentation

HTML

Draft legislation

PDF, 62.6 KB, 4 pages

This file may not be suitable for users of assistive technology.

Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email [email protected]. Please tell us what format you need. It will help us if you say what assistive technology you use.

Draft legislation accessible version

HTML

Explanatory note

ODT, 15.5 KB

This file is in an OpenDocument format

This file may not be suitable for users of assistive technology.

Request an accessible format.

If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email [email protected]. Please tell us what format you need. It will help us if you say what assistive technology you use.

Details

The measure requires large multinational businesses operating in the UK to maintain a master file and a local file in a prescribed and standardised format, as set out in the Organisation for Economic Cooperation and Development’s transfer pricing guidelines.

It also introduces a requirement to complete a summary audit trail, which is a short questionnaire detailing the main actions undertaken in preparing the local file.

The largest UK businesses in scope of the measure are those with a taxable presence in the UK (for example, through a UK company or permanent establishment) and are within the Country-by-Country Reporting regime (have global revenues of 750 million euros or more).

Published 20 July 2022