As previously reported, UK HMRC published Tax policies and consultations Spring 2021 on 23 March 2021, including several consultation documents. One of the consultations of particular concern for MNEs is a consultation on transfer pricing documentation, which runs until 1 June 2021.
One of the key areas considered in the consultation is Master and Local file requirements. Although HMRC has referenced OECD guidelines and the Master and Local file documentation, it has not introduced specifi…