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Overview of approach to transfer pricing risk

There is an agreed framework in relation to transfer pricing that sets out the process for handling enquiries, with each case passing through a series of steps or ‘stage gates’. This methodology aims to provide a structured, consistent approach with an expected time frame for resolution of 18 months. Please refer to the HMRC approach to transfer pricing enquiries guidance note for further details.

HMRC will undertake a full risk assessment prior to opening a transfer pricing enquiry, a procedure that emulates their general interactions with large businesses. If the result of this risk assessment process suggests that there is a low risk of a transfer pricing issue arising, the transfer pricing enquiry will not be pursued. HMRC states that a number of factors taken together, rather than individual indicators alone, will signal the existence of a transfer pricing risk.

The results of the risk assessment will be used to compile a business case that is required to open a transfer pricing enquiry. For this reason, HMRC’s own