Introduction

The UK follows OECD Guidelines and maintains a risk-based approach to enforcement. HMRC emphasizes strategic risk classification and cooperative compliance via the Business Risk Review (BRR+).

Key Features

• Legislation: Based on the Taxes Act 2010; fully aligned with OECD BEPS.

• Documentation: Master and local file required; country-specific details expected.

• CbCR: Mandatory for large MNEs; shared through treaty networks.

• APAs and MAPs: Available, with early engagement and bilateral scope prioritized.

Current Developments

• High scrutiny on intangibles, intragroup services, and financial arrangements.

• Supportive of Pillar One and Pillar Two adoption by 2025.

• Alignment with EU’s public CbCR regulations.

Conclusion

TP in the UK is shifting toward proactive transparency. MNEs should embrace documentation best practices, anticipate audit triggers, and align closely with OECD interpretations.