UK HMRC has launched a public consultation on the Transfer Pricing Records Regulations 2023, which introduces master file and local file requirements from 1 April 2023 for corporation tax purposes. The consultation closes at 11:45 pm on 31 January 2023.
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Draft regulations: The Transfer Pricing Records Regulations 2023
Consultation description
The draft statutory instrument requires Multinational Enterprises (MNEs) with turnover of €750m or more, operating in the UK, to keep and preserve a master file and local file in accordance with the OECD Transfer Pricing Guidelines.
The regulations have effect:
- for Corporation Tax purposes, in relation to accounting periods beginning on or after 1 April 2023
- for Income Tax purposes, in relation to the tax year 2024 to 2025 and subsequent years
The regulations also provide HMRC with the power to introduce, by way of a published notice, the requirement for MNEs to produce a Summary Audit Trail (SAT). This is a document covering the steps taken by members of an in-scope MNE in completing their local file. HMRC will undertake a separate public consultation on the SAT in 2023 and therefore the SAT requirement will not come into force on 1 April 2023. A decision on the SAT's commencement will be made following the conclusion of the public consultation.
Before submitting your views to transferpricingdocumentationconsultations@hmrc.gov.uk, we recommend that you read the draft statutory instrument published on this page.
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