UK: Consultation on transfer pricing documentation requirements

UK: Transfer pricing documentation requirements

HM Revenue & Customs (HMRC) this week opened a consultation on the UK’s transfer pricing documentation requirements. The consultation seeks input for updating the UK’s transfer pricing documentation requirements, and requests possible options and design ideas that could benefit UK business and HMRC.

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Read the consultation document [PDF 286 KB]

The consultation is open for comments until 1 June 2021.

The UK’s current transfer pricing documentation requirements are governed by non-specific legislative recordkeeping requirements that direct UK businesses to keep records needed to deliver correct and complete returns. As noted in the consultation document, it has been five years since the UK adopted a minimum standard for transfer pricing documentation, and now is seen as an appropriate juncture to consider whether the current level of implementation continues to best serve the requirements of HMRC and UK businesses.

The consultation document considers the case for updating and strengthening current transfer pricing documentation requirements to provide greater certainty for UK businesses, provide HMRC with better quality data to enable more efficient and targeted compliance interventions, and align the UK’s practice more closely with the transfer pricing documentation requirements of comparable tax administrations and the base erosion and profit shifting (BEPS) Action 13 final report.

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