Transfer pricing compliance: a guiding hand and a warning

Simon Wood

HMRC are clearly not happy with the standard of analysis and documentation that they are currently seeing, writes Simon Wood (BDO).

The main guidelines are presented across three parts and an annex:

managing compliance risk (aimed at UK ‘risk leads’ responsible for tax) (part 1);
common compliance risks (aimed at specialists covering planning analysis and documentation) (part 2);
design risks (transaction forms and approaches that HMRC view as high risk) (part 3); and
examples of helpful supporting records and information (annex A).

The guidelines are intended to help businesses in-house specialists and their advisers to understand HMRC’s expectations through:

practical end-to-end best practice guidance across a defined TP lifecycle;
promoting engagement across the business finance and tax functions;
emphasis on the importance of evidencing timely analysis of sufficient quality;
examples of insufficient and unhelpful approaches failures and common errors; and
qualitative...

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HMRC are clearly not happy with the standard of analysis and documentation that they are currently seeing, writes Simon Wood (BDO).

The main guidelines are presented across three parts and an annex:

managing compliance risk (aimed at UK ‘risk leads’ responsible for tax) (part 1);
common compliance risks (aimed at specialists covering planning analysis and documentation) (part 2);
design risks (transaction forms and approaches that HMRC view as high risk) (part 3); and
examples of helpful supporting records and information (annex A).

The guidelines are intended to help businesses in-house specialists and their advisers to understand HMRC’s expectations through:

practical end-to-end best practice guidance across a defined TP lifecycle;
promoting engagement across the business finance and tax functions;
emphasis on the importance of evidencing timely analysis of sufficient quality;
examples of insufficient and unhelpful approaches failures and common errors; and
qualitative...

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes: