Transfer pricing compliance: a guiding hand and a warning

Simon Wood

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 indicators of compliance risk.

The format of the guidelines is to highlight and list things that HMRC see in a good...

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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 indicators of compliance risk.

The format of the guidelines is to highlight and list things that HMRC see in a good...

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: