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.
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.