Statutory Instruments
2022 No. 1147
CORPORATION TAX
INCOME TAX
The Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2022
Made
3rd November 2022
Laid before the House of Commons
8th November 2022
Coming into force
1st January 2023
The Treasury make the following Order in exercise of the powers conferred by section 164(4)(b) of the Taxation (International and Other Provisions) Act 2010( 1 ).
Citation, commencement and effect
1. —(1) This Order may be cited as the Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2022 and comes into force on 1st January 2023.
(2) This Order has effect (in relation to provision made or imposed at any time)—
(a) for corporation tax purposes, for accounting periods beginning on or after 1st January 2023, and
(b) for income tax purposes, for the tax year 2023-24 and subsequent tax years.
Designation
2. For the purposes of section 164(4) of the Taxation (International and Other Provisions) Act 2010, the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 published by the OECD on 20th January 2022( 2 ) are designated for the time being.
Revocation
3.The Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2018( 3 ) is revoked.
Amanda Solloway
Nigel Huddleston
Two of the Lords Commissioners of His Majesty's Treasury
3rd November 2022
2010 c. 8 ; section 164(4) was substituted by section 58 of the Finance Act 2011 (c. 11) and amended by section 75(1) of the Finance Act 2016 (c. 24) .
A paper copy of the guidelines is available for inspection at the HMRC address provided in the Explanatory Note. The guidelines are also available online at https://www.oecd.org/tax/transfer-pricing/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-20769717.htm , ISBN 978-92-64-52691-4 (print) and ISBN 978-92-64-92191-7 (PDF).
The Model Tax Convention on Income and on Capital 2010 (Full Version) can be found here: https://read.oecd-ilibrary.org/taxation/model-tax-convention-on-income-and-on-capital-2010_9789264175181-en#page1 .