The Transfer Pricing Records Regulations, SI 2023/818, introduce the requirement for in-scope entities to prepare and retain standardised 'master file' and 'local file' transfer pricing records, in line with the record-keeping requirements in the OECD Transfer Pricing guidelines for multinational enterprises and tax administrations 2022.
As KPMG notes in a client briefing, ‘these new regulations mark a major change as, for the first time, the UK has prescriptive mandatory TP documentation requirements’.
The obligation to keep and preserve records in this format applies for corporation tax purposes in relation to returns for accounting periods beginning on or after 1 April 2023, and for income tax purposes from the tax year 2024/25.
The Transfer Pricing Records Regulations, SI 2023/818, introduce the requirement for in-scope entities to prepare and retain standardised 'master file' and 'local file' transfer pricing records, in line with the record-keeping requirements in the OECD Transfer Pricing guidelines for multinational enterprises and tax administrations 2022.
As KPMG notes in a client briefing, ‘these new regulations mark a major change as, for the first time, the UK has prescriptive mandatory TP documentation requirements’.
The obligation to keep and preserve records in this format applies for corporation tax purposes in relation to returns for accounting periods beginning on or after 1 April 2023, and for income tax purposes from the tax year 2024/25.