On 9 November 2022, the UK Official Gazette published Statutory Instrument No. 2022/1147, on transfer pricing (TP) guidelines. The statutory instrument outlines the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, for the purpose of section 164(4) of the Taxation (International and Other Provisions) Act 2010. The Order comes into force on 1 January 2023.
This instrument amends a reference to “transfer pricing guidelines” within the relevant legislation to point to the most recent revisions to the Organization for Economic Co-operation and Development (OECD)’s Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which are the internationally agreed standard for application of the arm’s length principle for transfer pricing purposes. On 20 January 2022, the OECD published updated Transfer Pricing Guidelines of 2022. This instrument also revokes the Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2018 (S.I. 2018/266) in its entirety.
