The Transfer Pricing Records Regulations 2023
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2 Meaning of relevant person and relevant tax period
(1) “Relevant person” means— (a) a company which may be required by a notice under paragraph 3 of Schedule 18 to the Finance Act 1998 (company tax return) to make and deliver a return for a relevant tax period, (b) a person who may be required by a notice under section 8A of TMA 1970 (trustees return) to make and deliver a return for a relevant tax period, or (c) a person who may be required by a notice under section 12AA of TMA 1970 (partnership return) to make and deliver a return for a relevant tax period. (2) “Relevant tax period” means a tax period— (a) in respect of which— (i) the person mentioned in paragraph (1)(a), (ii) in relation to the person mentioned in paragraph (1)(b), the trustees of the trust concerned, or (iii) in relation to the person mentioned in paragraph (1)(c), the partnership to which the partnership return relates, together with one or more other enterprises, constitutes an MNE Group, and (b) in respect of which the MNE Group meets the threshold requirement within the meaning of regulation 3(2) to (4) of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016. (3) In paragraph (2), “tax period” has the meaning given in paragraph 28(g) of Schedule 24 to the Finance Act 2007.
2 Meaning of relevant person and relevant tax period
(1) “Relevant person” means— (a) a company which may be required by a notice under paragraph 3 of Schedule 18 to the Finance Act 1998 (company tax return) to make and deliver a return for a relevant tax period, (b) a person who may be required by a notice under section 8A of TMA 1970 (trustees return) to make and deliver a return for a relevant tax period, or (c) a person who may be required by a notice under section 12AA of TMA 1970 (partnership return) to make and deliver a return for a relevant tax period. (2) “Relevant tax period” means a tax period— (a) in respect of which— (i) the person mentioned in paragraph (1)(a), (ii) in relation to the person mentioned in paragraph (1)(b), the trustees of the trust concerned, or (iii) in relation to the person mentioned in paragraph (1)(c), the partnership to which the partnership return relates, together with one or more other enterprises, constitutes an MNE Group, and (b) in respect of which the MNE Group meets the threshold requirement within the meaning of regulation 3(2) to (4) of the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016. (3) In paragraph (2), “tax period” has the meaning given in paragraph 28(g) of Schedule 24 to the Finance Act 2007.
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