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

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Draft legislation

PDF, 62.6 KB, 4 pages

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Draft legislation accessible version

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Explanatory note

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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