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HMRC internal manual

International Manual

Transfer pricing: risk assessment: conducting a transfer pricing risk assessment: lack of information

Risk assessment - lack of information

Information will not be available from all the possible sources suggested in this chapter. Nor will the available information build up a complete picture of all the transactions between the company and connected businesses. The aim is to acquire as complete an understanding as possible before taking a decision. The risk assessment on international issues should not be left to the last few days of the enquiry window and the review should be planned at an early stage.

Cases should not be ignored just because there is not enough information immediately to hand to form the basis of a risk assessment.

It is unlikely that information will be needed from an associated company outside the UK for the purposes of the risk assessment. Parent company accounts can normally be obtained from the business’s website. If exceptionally there is important information held overseas which the business either cannot or will not provide through the UK company, then consider a request for exchange of information under the appropriate double taxation agreement. See INTM483060 for advice on how to go about this.

Where case teams meet with the business as part of the transfer pricing risk assessment process (see INTM482130), concerns about a lack of information should arise much less often. It must be borne in mind that such discussions are part of the risk assessment process and are not held as part of an enquiry - the boundary between the two must remain clear at all times. Case teams should read the guidance on real time working at INTM480040 onwards.