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Transfer pricing: documentation proposals and disputes

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The government is consulting on proposals for mandatory transfer pricing documentation in the form of the OECD recommended master file and local file for large MNEs, plus supporting evidence log, and an international dealings schedule for all businesses subject to UK transfer pricing rules. The latter two of these, in particular, have the potential to impose a significant additional compliance burden. The consultation suggests the proposals should lead to fewer and more focused transfer pricing enquiries which can be resolved more quickly because the facts are better understood at the outset. However, in practice those objectives may be difficult to achieve.

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