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UK Introducing New Transfer Pricing Documentation Requirements for MNEs in the UK

21 July 2022

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Proposed Changes

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United Kingdom

UK HMRC has published a policy paper on draft legislation that introduces powers for regulations to be made in relation to required transfer pricing documentation. It is proposed that such powers will be used to make regulations that will introduce a requirement for large multinational businesses operating in the UK to keep and preserve a Master file and a Local file in a prescribed and standardized format, as set out in the OECD's Transfer Pricing Guidelines. It is also proposed to use the power to introduce a requirement to complete a Summary Audit Trail, which is a questionnaire detailing the...