UK updates tax provision to reflect latest OECD transfer pricing guidance

The update comes into effect for accounting periods beginning on or after January 1, 2023, for corporation tax purposes.

The UK government has updated the country’s transfer pricing legislation to add a reference to the latest OECD Transfer Pricing Guidelines.

UK transfer pricing legislation is found at Part 4 of the Taxation (International and Other Provisions) Act 2010 (TIOPA).

In January this year, the OECD published updated Transfer Pricing Guidelines (the 2022 OECD Transfer Pricing Guidelines). The OECD Transfer Pricing Guidelines are internationally agreed standard for application of the arm’s length principle for transfer pricing purposes.

The Taxation (International and Other Provisions) Act, 2010 Transfer Pricing Guidelines Designation Order 2022, amends a reference to “transfer pricing guidelines” in section 164(1) of TIOPA to point to the most recent revisions to the OECD’s Transfer Pricing Guidelines.

The update comes into effect for accounting periods beginning on or after January 1, 2023, for corporation tax purposes.