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HMRC has published new guidelines for UK businesses within the scope of UK transfer pricing rules.
The new guidelines (which can be found here) are intended to be read alongside HMRC’s transfer pricing guidance in its International Manual (from INTM410000 to INTM480000) and are predominantly aimed at helping businesses reduce uncertainty in their transfer pricing compliance approaches by:
The new guidelines are presented in three parts - with Parts 2 and 3 aimed at in-house or advisory transfer pricing specialists and UK compliance risk leaders (such as UK tax compliance managers, UK finance directors, UK finance controllers, Senior Accounting Officers (SAOs) and UK environmental, social and governance (ESG) leads).
The three parts of HMRC’s new guidance cover:
There is also an annex which provides examples of what HMRC consider to be helpful supporting records and information.
Please contact us, or your regular Baker McKenzie contact, should you have any questions or want to discuss further.
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