Help with common risks in transfer pricing approaches — GfC7
Find out about best practice approaches to transfer pricing to lower risk and avoid common mistakes.
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These guidelines are for UK businesses which fall within the scope of UK transfer pricing rules.
These guidelines and examples are designed to clarify and help you understand HMRC’s expectations as you plan and implement transfer pricing compliance approaches. They also set out what HMRC considers best practice compliance and higher risk approaches.
UK transfer pricing compliance risk is a key concern of finance and risk functions within businesses, and their advisers or in-house tax teams. These guidelines are tailored to the different needs of different audiences. This is reflected in the following parts:
Managing compliance risk for UK businesses (part 1) — should be read by those managing UK transfer pricing risk to:
- determine the scope of work
- build governance, controls and checks
- evidence the arm’s length return
Common compliance risks (part 2) — is for specialists and includes:
- indicators of higher risk through the compliance process
- HMRC recommendations for best practice compliance approaches
- how to support and evidence an arm’s length return
Indicators of transfer pricing policy design risk (part 3) — for specialists and covers common risks in transfer pricing design and implementation.