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 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).
