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Wai Hung Wan

Wai-Hung Wan is a Senior Economist in Baker McKenzie London office.

Since 2015, the UK has adopted the minimum standard of required transfer pricing documentation articulated in BEPS Action 13 (“Guidance on Transfer Pricing Documentation and Country-by-Country Reporting”), namely Country-by-Country-Reporting (CbCR). In its latest consultation paper, HMRC have set out their intention to move away from the BEPS Action 13 minimum standard and to require taxpayers of large multinational enterprise groups (MNE groups) to prepare a master file and local files together with supplemental evidence logs. 

HMRC have also set out a proposal for all UK taxpayers that fall under UK transfer pricing rules to submit an international dealings schedule (IDS) – a highly structured form to capture specific intragroup transactions and activities. If introduced, this would be a significant step change from current documentation requirements and one that will likely increase the compliance burden for many.