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HMRC internal manual

International Manual

HM Revenue & Customs
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Transfer Pricing: Operational guidance: scope of the operational guidance

This operational guidance consists of the following chapters.


The chapter beginning at INTM481000 sets out the governance for transfer pricing work and explains how it applies to the stages of an enquiry. It also describes the role of the Transfer Pricing Group and how they can help.

Risk assessment

The chapter beginning at INTM482000 explains the principles of assessing tax risk in applying transfer pricing rules. It considers such issues as building an understanding of the business, the amount of tax at risk, resources, and specific factors that might influence pricing.

Working a transfer pricing case

The chapter beginning at INTM483000 looks at some practical and compliance issues involved in working a transfer pricing case, from opening the case, deciding on the information and documents needed, through to settlement.

Examining transfer pricing reports

The chapter beginning at INTM484000 is concerned with examining transfer pricing reports. In many cases case teams will be presented with a transfer pricing report prepared for the business under review. A good transfer pricing report can be a great help in resolving concerns promptly. But in practice such reports vary greatly in scope and quality. The guidance will help teams to evaluate the information and conclusions in a report and indentify what is missing from it.

Establishing the arm’s length price - evidence gathering

The chapter beginning at INTM485000 provides practical guidance on how to establish the transfer price. If flaws are found in the transfer pricing used by a business, case teams will need to propose a better alternative approach to put in its place. This chapter looks at establishing the facts and how to find and use comparables.