ARTICLE · 01 AUGUST 2023

UK Transfer Pricing Documentation Changes From 1 April 2023

UHY Hacker Young LLP

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At the time of the OECD BEPS initiative, the UK implemented the Country-by-Country minimum standard but did not introduce specific requirements regarding master file and local file.

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Changes to the transfer pricing documentation required by the UK tax authorities take effect for accounting periods commencing on or after 1 April 2023.

UK businesses in scope of the new requirements are those with a taxable presence in the UK (e.g. through a UK company or permanent establishment) and are within the Country-by-Country Reporting regime (i.e. where they have global revenues of €750 million or more).

By way of background, transfer pricing is a means of pricing transactions between connected parties, based on the internationally recognised "arm's length principle" which seeks to determine what the price would have been if the transactions had been carried out under comparable conditions by independent parties.

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