- The government has published legislation to require large businesses to maintain, and provide on request, master file and local file documentation. This follows the public consultation in 2021.
- HMRC have decided to separate the introduction of the master file and local file obligations from the introduction of a summary audit trail (SAT).
- The form/template of the summary audit trail questionnaire has not yet been released and a decision on implementation will be made following a public consultation.
- Timing: The master file and local file documentation requirements apply for accounting periods beginning on or after 1 April 2023.
Resources (click to open)
- Transfer pricing records regulations for master file and local file published (Deloitte tax@hand, July 2023)
- Draft transfer pricing records regulations published (Deloitte tax@hand, December 2022)
- Introduction of new summary audit trail documentation requirement delayed (Deloitte tax@hand, December 2022)
- Understanding And Preparing For The New UK TP Documentation Requirements (Deloitte EMEA Dbriefs webcast, February 2022)
