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HMRC internal manual

International Manual

Transfer pricing: risk assessment: introduction

Structure of this guidance

This chapter covers risk assessment and selection of transfer pricing cases for enquiry. It’s divided into four sections:

  • Issues to consider before starting a transfer pricing enquiry: INTM482030 onwards
  • Transfer pricing risk indicators: INTM482040 onwards
  • Conducting a transfer pricing risk assessment: INTM482130 onwards
  • Summary and conclusions: INTM482170 

The guidance in this chapter gives advice on how to risk assess and select cases for a transfer pricing enquiry. There will be occasions when it will not be appropriate to examine a company’s transfer pricing arrangements and this chapter also highlights some of these.

There are governance processes which must be followed both before commencing an enquiry and as it progresses - see INTM481000 onwards.

Readers who are new to transfer pricing should first read the guidance covering transfer pricing legislation and principles at INTM412000 onwards.

Thin capitalisation cases

Risk assessment of thin capitalisation issues is covered separately at INTM513010 onwards.