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B4.159 Transfer pricing documentation—overview

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. However, from April 2023, more formalised transfer pricing documentation requirements apply to multinational enterprises within the country-by-country reporting regime (see below).

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

1. Ìý

   •ÌýÌýÌýÌý OECD guidance, see B4.160

2. Ìý

   •ÌýÌýÌýÌý HMRC guidance, see B4.161

In addition to the self-assessment requirement there are further documentation obligations for multinational enterprises that are within the country-by-country reporting regime (see below).

The OECD Guidelines² highlight that maintaining well prepared transfer pricing documentation should assure the tax administration that the taxpayer has analysed the position that has been reported on its tax return given the available data