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HMRC internal manual

International Manual

Transfer pricing: operational guidance: governance: the Transfer Pricing Group

What is the Transfer Pricing Group?

The Transfer Pricing Group (TPG) is a body of tax and other specialists within HMRC who are dedicated to working transfer pricing and thin capitalisation enquiries. These personnel are drawn from the following directorates:

  • CSTD Business, Assets & International (BAI)
  • Large Business Service (LBS)
  • Local Compliance (LC)
  • Specialist Investigations (SI)
  • Knowledge Analysis and Intelligence (KAI)

The TPG is headed by the Transfer Pricing Board composed of senior managers from each of the directorates. It is accountable to HMRC’s Large Business Tactical Delivery Board and sets the strategic direction for the department’s handling of transfer pricing risk.

Responsible to the Transfer Pricing Board are two Transfer Pricing Panels, one for the LBS and one for LC. These are the main decision-making bodies and comprise representatives from each of the directorates and the leaders of each of the Transfer Pricing Units.

The day-to-day operational function of the TPG is carried out by Transfer Pricing Specialists organised geographically into Transfer Pricing Units. They are wholly engaged in working transfer pricing enquiries in partnership with case teams and other members of the wider transfer pricing community within HMRC.

Over and above their membership of the Transfer Pricing Board and Transfer Pricing Panels, the BAI, SI and KAI directorates contribute policy, technical and operational specialism’s through designated personnel available to the TPG. Early and frequent use of this resource by the Transfer Pricing Specialists is an important feature of the way in which transfer pricing enquiries should be worked.

Further guidance on the role of case teams and other members of the wider transfer pricing community is contained in INTM481080.