UK HRMC has published guidance on the transfer pricing records requirements for permanent establishments in the UK in the context of the amendments made by Finance (No. 2) Act 2023 (previous coverage). --- INTM450021 - Transfer pricing records: Permanent Establishments The transfer pricing records legislation does not apply to permanent establishments that are part of an MNE group that meets the CbCR threshold ('the MNE group test' – see INTM450020). That is because Schedule 5 to Finance (No. 2) Act 2023 defines the relevant transfer pricing records as records that may relate to the calculation of profits or losses in...