Transfer pricing documentation
Read the full outcome
Detail of outcome
Following the public consultation on transfer pricing documentation, the government has decided that it will legislate to require the largest businesses to maintain a master file and local file, and a supporting summary audit trail, to take effect from April 2023.
The government will not introduce an International Dealing Schedule but will keep this policy area under review.
Original consultation
Consultation description
This consultation seeks views on the case for clarifying and strengthening transfer pricing documentation requirements.
Currently, HMRC’s transfer pricing documentation requirements are governed by generic record keeping requirements for businesses to keep sufficient records to deliver correct and complete returns.
This consultation will explore potential changes to:
- transfer pricing record keeping requirements for the largest businesses
- the introduction of a new tax filing requirement for all businesses affected by transfer pricing regulations
Such changes could provide businesses with greater certainty about transfer pricing documentation requirements and provide HMRC with high quality data in a standardised format to target resources on the most significant areas of transfer pricing risk and reduce the time taken to complete compliance interventions.
Documents
Updates to this page
Last updated 30 November 2021 + show all updates
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Published a summary of responses to the consultation.
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First published.