For multinational groups operating in the UK, Action 13 compliance is a central part of transfer pricing documentation. It reshaped how large groups report where their profits are earned and taxed.
What Is Action 13?
Action 13 introduced a three-tiered approach to transfer pricing documentation: a master file overview of the group, a local file covering specific transactions, and country-by-country (CbC) reporting. Together these give tax authorities a clearer picture of global activities.
Who Needs to Comply?
CbC reporting generally applies to large groups above a global revenue threshold. Even without full CbC reporting, many groups still need master and local files, so Action 13 compliance is relevant to a wide range of international businesses.
Why It Matters
The aim is transparency. Consistent documentation across jurisdictions helps authorities spot mismatches between where activity happens and where profits are reported, and it is also a business’s first line of defence in any enquiry.
How TaxDigit Can Help
Our Guildford-based team helps groups meet their Action 13 compliance obligations with clear, defensible documentation. Get in touch to review your transfer pricing position.
Action 13 Compliance: UK-Wide Transfer Pricing Support
Action 13 compliance affects multinational groups operating right across the United Kingdom, not only those near our Guildford head office. TaxDigit helps UK-based groups and inbound multinationals prepare master files, local files and country-by-country reports that stand up to HMRC scrutiny.
Our chartered certified accountants make transfer pricing documentation practical, aligning your reporting with the OECD framework while keeping it proportionate to your size and structure. We support clients UK-wide, both remotely and on-site.
How we help with Action 13 compliance
- Preparing master file and local file documentation to the required standard
- Assessing whether your group meets the country-by-country reporting threshold
- Aligning intra-group pricing policies with the arm’s length principle
- Reviewing existing documentation for gaps before an HMRC enquiry
- Coordinating Action 13 reporting with your wider corporation tax compliance
HMRC sets out the UK documentation requirements in detail here: HMRC transfer pricing documentation requirements for UK businesses.
Frequently Asked Questions
What is Action 13 compliance?
Action 13 is the OECD standard for transfer pricing documentation, introducing the master file, local file and country-by-country reporting so tax authorities can see where group profits are earned and taxed.
Does my group need country-by-country reporting?
Full CbC reporting generally applies to large groups above a global revenue threshold, but many smaller groups still need master and local files.
Can TaxDigit help if I am not based in Guildford?
Yes. We provide Action 13 compliance and transfer pricing support to clients UK-wide, remotely and from our Guildford office.