New Transfer Pricing Registration Rules in the UK

September 5, 2023

As of April 2023, the maintenance of the Transfer Pricing documentation through a template will become a requirement for UK companies within the UK Transfer Pricing legislation. Likewise, the Transfer Pricing Records Regulations 2023 were published on July 19, 2023.


After the Spring Finance Bill 2023 was passed, the Government published a statutory instrument implementing the new Transfer Pricing documentation requirements for the UK. 

These new regulations set a major change as, for the first time, the UK has mandatory prescriptive Transfer Pricing documentation requirements.   


The UK government published regulations on Transfer Pricing records, applicable from April 1, 2023, for corporate tax and from the fiscal year 2024-2025 for income tax. 

Innovation Reasons

The argument of the UK Crown Revenue and Customs Office for requiring a particular format is the guarantee of a consistent approach. This requirement is based on the OECD Transfer Pricing Guidelines.