Transfer pricing documentation

This consultation seeks views on the case for clarifying and strengthening transfer pricing documentation requirements.

Currently, HMRC’s transfer pricing documentation requirements are governed by generic record keeping requirements for businesses to keep sufficient records to deliver correct and complete returns.

This consultation will explore potential changes to:

• transfer pricing record keeping requirements for the largest businesses
• the introduction of a new tax filing requirement for all businesses affected by transfer pricing regulations

Such changes could provide businesses with greater certainty about transfer pricing documentation requirements and provide HMRC with high quality data in a standardised format to target resources on the most significant areas of transfer pricing risk and reduce the time taken to complete compliance interventions.