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Policy paper: 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.

Documents

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 Developmentā€™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 15 March 2023

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.

Documents

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 Developmentā€™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 15 March 2023