Record keeping

There are no special rules relating to record keeping and transfer pricing and instead the normal rules summarised at ¶181-900 apply. However, HMRC have provided guidance on how these rules will be interpreted for transfer pricing purposes (see at HMRC International Manual, INTM 483030), and have previously indicated that the guidance provided by the OECD will be followed (former version of HMRC International Manual, from INTM 433020ff.). The OECD Guidelines (see ¶774-500) impose obligations on taxpayers, place restrictions on tax administrations and provide guidance on the information required to determine a transfer price.

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