The UK has published the Transfer Pricing Records Regulations 2023, which provide for the formal introduction of Local file and Master file requirements. Amendments were made to allow for the regulations as part of the Finance (No. 2) Act 2023.
The regulations apply to a relevant person in relation to a relevant tax period:
- A "relevant person" means a company, trustee, or partnership that may be required to make and deliver a tax return; and
- A "relevant tax period" means a tax period in r…