The Taxation (International and Other Provisions) Act 2010 Transfer Pricing Guidelines Designation Order 2022
UK transfer pricing rules are based on the internationally agreed arm’s length principle, which is now set out in Article 9 of the Model Tax Convention on Income and on Capital 2010. Guidance on applying the arm’s length principle is set out in the Organisation for Economic Co-operation and Development (“OECD”) Transfer Pricing Guidelines, which are periodically updated and republished, and are referred to in UK transfer pricing legislation.