Legislation will be introduced in Finance Bill 2016 to amend the definition of “transfer pricing guidelines” within the current legislation to incorporate the revisions agreed to the OECD Guidelines by the joint OECD/G20 BEPS project.
The measure will have effect for section 164(4) Taxation (International and Other Provisions) Act 2010 for Corporation Tax purposes in relation to accounting periods beginning on or after 1 April 2016 and for Income Tax purposes in relation to the tax year 2016 to 2017 and subsequent tax years. For section 357GE(1) Corporation Tax Act 2010 the measure will have effect for accounting periods beginning on or after 1 April 2016.
BEPS Actions 8 – 10 clarify the 2010 Guidelines so can be applied retrospectively.
The HMRC budget paper is here: https://bit.ly/1ST6RYF