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Detailed Content Requirements for Files
Master and Local File content is prescribed in The Transfer Pricing Records Regulations 2023. The Local File must be in English and cover company structure, transaction details, comparables, and tax impact per HMRC guidance.
Country-by-Country Reporting & Public Disclosure
UK-headed groups meeting the €750 million threshold must file annual CbC reports to HMRC within 12 months post-year end. The UK is monitoring EU's public CbC regime and may require public disclosure in the future.
Response to Global Minimum Tax (Pillar 2)
The UK has legislated a 15% minimum tax for large multinational groups following OECD Pillar 2. The Multinational Top-up Tax began for periods after December 31, 2023, with deadlines and compliance aligned to international rules.
Guidance on Statistical Methods, Range, and Loss Markers
HMRC guidance (aligned to OECD) allows for arm's length ranges and interquartile ranges. Loss-making comparables and outliers may be excluded if reliability is improved.
Advanced Pricing Agreements (APA) Framework
HMRC offers APA programs (unilateral, bilateral, multilateral) providing certainty for future transfer pricing positions. The UK APA program follows OECD BEPS recommendations.
Focus Areas: Intangibles, Financial Transactions, and Hard-to-Value Assets
HMRC's recent focus is robust documentation and sound pricing of intangibles, cross-border financial transactions, and hard-to-value assets, mirroring OECD and UK-specific risks.
IRS Unveils Simplified Approach for Transfer Pricing Compliance
The IRS has launched a new Simplified and Streamlined Approach (SSA) to transfer pricing. Starting with the 2025 tax year, companies can elect this safe harbor method for routine marketing and distribution activities, reducing compliance burdens and promoting alignment with international standards.
U.S. Transfer Pricing Shifts Closer to Global Tax Standards
The latest IRS revisions bring U.S. transfer pricing policy further in line with evolving global norms from the OECD. Taxpayers should closely monitor international developments, as these changes will directly affect their U.S. compliance strategies.
U.S. Aligns Transfer Pricing for Distributors with OECD Amount B
A policy shift brings U.S. transfer pricing rules for low-risk distributors and agents into harmony with the OECD's Amount B guidance. The new framework offers standardized operating margins, helping multinational taxpayers plan and report with greater certainty.
Interim IRS Guidance Eases Transition to New Transfer Pricing Rules
IRS Notice 2025-04 provides taxpayers with interim rules as the agency works to finalize updated transfer pricing regulations. Companies adopting the SSA can rely on these guidelines now, provided required documentation is in place for audit readiness.
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