Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
On 23 March 2021 the government published a consultation on proposals to update and strengthen the transfer pricing documentation requirements for UK businesses.
The consultation suggests that the proposals would enable HMRC to:
conduct better risk assessment;
direct transfer pricing enquiries more appropriately; and
reduce the time taken to establish the facts when enquiries are opened.
HMRC’s desire for more and better quality information seems fairly clearly to support a continued focus on revenue-raising from transfer pricing and diverted profits tax audits. In an area notorious for long-running fact-heavy disputes their objectives are laudable ones which could also bring benefits for business if achieved.
However some of the proposed documentation and reporting requirements go beyond OECD minimum standards and seem likely to...
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Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
On 23 March 2021 the government published a consultation on proposals to update and strengthen the transfer pricing documentation requirements for UK businesses.
The consultation suggests that the proposals would enable HMRC to:
conduct better risk assessment;
direct transfer pricing enquiries more appropriately; and
reduce the time taken to establish the facts when enquiries are opened.
HMRC’s desire for more and better quality information seems fairly clearly to support a continued focus on revenue-raising from transfer pricing and diverted profits tax audits. In an area notorious for long-running fact-heavy disputes their objectives are laudable ones which could also bring benefits for business if achieved.
However some of the proposed documentation and reporting requirements go beyond OECD minimum standards and seem likely to...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
