Commentary

B4.161 Transfer pricing documentation—HMRC guidance

Business tax
Business tax | Commentary

B4.161 Transfer pricing documentation—HMRC guidance

Business tax | Commentary

B4.161 Transfer pricing documentation—HMRC guidance

HMRC guidance on transfer pricing documentation

HMRC manuals set out1 how they interpret the general self-assessment record keeping requirements for transfer pricing purposes. This guidance states their commitment to interpreting the legislation by reference to Chapter V of the OECD Guidelines2. Chapter V is designed to assist both tax administrations in developing their approaches to documentation rules and taxpayers in identifying records that would be helpful in demonstrating that their pricing methodologies satisfy the arm's length principle, see B4.160.

The likely components of transfer pricing documentation are as follows3:

  1.  

    •     functional analysis

  2.  

    •     reviewed transactions

  3.  

    •    

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