Draft regulations: The Transfer Pricing Records Regulations 2023
We welcome views on the draft regulations for the Transfer Pricing Documentation measure, which supports the measure’s primary legislation.
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.