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HMRC internal manual

International Manual

Transfer pricing: operational guidance: governance: introduction


Proposal 5 of the Review of Links with Large Business, which can be read by clicking on this link, committed HMRC to resolving new transfer pricing enquiries within

  • 18 months for the large majority of cases, and
  • 36 months for those which are particularly complex and high risk

The Transforming Transfer Pricing Project determined that the best way to ensure that - and to deliver a performance shift in the effectiveness and consistency with which transfer pricing enquiries were worked - was to develop not only a different structure but also entirely new governance procedures.

The central plank of these procedures is the governance process to which all active and potential transfer pricing enquiries are subject.

Important note

A transfer pricing enquiry must not in any circumstances be opened (or any approach made to a customer that might be construed as a transfer pricing enquiry) or settled unless approval to do so has been obtained from the Transfer Pricing Panels or Transfer Pricing Board under the appropriate governance procedure.