The government has announced further documentation requirements that apply from April 2023. The following is an extract from the HM Treasury document CP751, entitled Autumn Statement 2022 (para. 5.40), with paragraph spacing added for greater clarity:
“From April 2023, large multinational businesses operating in the UK will be required to keep and retain transfer pricing documentation in a prescribed and standardised format, set out in the OECD’s Transfer Pricing Guidelines (Master File and Local File). This will give businesses certainty on the appropriate documentation they need to keep and enable HM Revenue and Customs (HMRC) to effectively identify risks and conduct transfer pricing investigations more efficiently.
This will be legislated for in Spring Finance Bill 2023.
HMRC will continue to consult on a Summary Audit Trail which is a questionnaire that businesses would be required to complete that covers the main steps undertaken in preparing the Local File.”