Consultation outcome

Transfer pricing documentation

• From: HM Revenue & Customs
• Published: 23 March 2021
• Last updated: 30 November 2021 — See all updates

This consultation has concluded

Read the full outcome

Transfer pricing documentation - summary of responses (open document format)

ODT, 69 KB

This file is in an OpenDocument format

Transfer pricing documentation - summary of responses

PDF, 211 KB, 20 pages

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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.

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Original consultation

Summary

We welcome views on options for updating transfer pricing documentation requirements.

This consultation ran from
9:30am on 23 March 2021 to 11:45pm on 1 June 2021

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

Transfer pricing documentation - consultation

PDF, 287 KB, 24 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 different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Transfer pricing documentation - consultation (open document format)

ODT, 56.3 KB

This file is in an OpenDocument format

Published 23 March 2021
Last updated 30 November 2021 + show all updates

1. 30 November 2021

   Published a summary of responses to the consultation.

2. 23 March 2021

   First published.