Commentary

B4.160 Transfer pricing documentation—OECD guidance

Business tax
Business tax | Commentary

B4.160 Transfer pricing documentation—OECD guidance

Business tax | Commentary

Transfer pricing documentation

B4.160 Transfer pricing documentation—OECD guidance

The transfer pricing rules do not impose a separate tax return requirement on taxpayers. Instead, the rules apply in a self-assessment environment. The general self-assessment rules require that taxpayers keep sufficient records to enable them to make a correct and complete return1. This applies equally to transfer pricing as it does to all other matters covered in a return.

There is guidance on what transfer pricing documentation should be maintained which has been issued by the following bodies:

  1.  

    •     OECD guidance, see below

  2.  

    •     HMRC guidance, see B4.161

In addition to the self-assessment requirement there is (for accounting periods starting on or after 1 January 2016) a country-by-country reporting requirement for (broadly) UK-resident parent entities of multinational enterprises with a consolidated group turnover of €750m or more2, this satisfies part of the OECD documentation guidelines. For details of country-by-country reporting see B4.162.

The OECD

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