UK consulting on draft transfer pricing records regulations

The UK tax authority is consulting on the draft Transfer Pricing Records Regulations, 2023.

The draft statutory instrument requires Multinational Enterprises (MNEs) with turnover of EUR 750 million 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 also provide HM Revenue and Customs (HMRC) with the power to require MNEs to produce a Summary Audit Trail – a document covering the steps taken by members of an in-scope MNE in completing their local file. 

The regulations have effect for corporation tax purposes, in relation to accounting periods beginning on or after April 1, 2023.

Comments must be received by January 31, 2023.