25 March 2021
As previously reported, UK HMRC published Tax policies and consultations Spring 2021 on 23 March 2021, including several consultation documents. One of the consultations of particular concern for MNEs is a consultation on transfer pricing documentation, which runs until 1 June 2021.
One of the key areas considered in the consultation is Master and Local file requirements. Although HMRC has referenced OECD guidelines and the Master and Local file documentation, it has not introduced specified requirements for the preparation and submission of such documentation. In this respect, the consultation is seeking views on the introduction of a mandatory requirement for MNEs within CbC reporting groups to provide HMRC with a copy of the Master file upon request and to keep (and produce on request) a Local file.
In addition to the Master and Local file requirements, the consultation is also seeking views on the introduction of requirements for the submission of an international dealings schedule on cross border transactions.
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