Draft regulations: The Transfer Pricing Records Regulations 2023
Detail of outcome
We thank those that took the time to review and respond to this technical consultation. We are considering the responses and will amend the regulations where necessary. We will update this page with a link to the final regulations once they are published.
Original consultation
Consultation description
The draft statutory instrument requires Multinational Enterprises (MNEs) with turnover of €750m or more, operating in the UK, to keep and preserve a master file and local file in accordance with the OECD Transfer Pricing Guidelines.
The regulations have effect:
- for Corporation Tax purposes, in relation to accounting periods beginning on or after 1 April 2023
- for Income Tax purposes, in relation to the tax year 2024 to 2025 and subsequent years
The regulations also provide HMRC with the power to introduce, by way of a published notice, the requirement for MNEs to produce a Summary Audit Trail (SAT). This is a document covering the steps taken by members of an in-scope MNE in completing their local file. HMRC will undertake a separate public consultation on the SAT in 2023 and therefore the SAT requirement will not come into force on 1 April 2023. A decision on the SAT’s commencement will be made following the conclusion of the public consultation.
Before submitting your views to transferpricingdocumentationconsultations@hmrc.gov.uk, we recommend that you read the draft statutory instrument published on this page.
Documents
Updates to this page
Published 21 December 2022Last updated 21 February 2023 + show all updates
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Concluded the consultation.
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First published.