Major Transfer Pricing Documentation Guidance Issued by United Kingdom

Extensive transfer pricing documentation guidance has been released by the UK tax authority, clarifying many matters hitherto unspecified by them. These include (i) the introduction of a materiality threshold for documentation; (ii) guidance on the extent to which aggregation of transactions is acceptable; and (iii) the obligation to update data on comparables every year. Although submitting a Master file and Local File is only compulsory for the largest groups, the guidance states a strong expectation that all taxpayers should use this format in the future.