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HMRC internal manual

International Manual

Transfer pricing: operational guidance: working a transfer pricing case: opening the case

Conducting an effective case

A clear strategy from the outset is essential. Case teams should bear in mind at all times that the purpose of a transfer pricing enquiry is to test controlled transactions against the arm’s length principle; see INTM412020. The team’s strategy should seek to identify and focus on the main areas of risk whilst balancing input with resource available, including the time which may potentially be required if a negotiated settlement cannot be reached.

Risk assessment

A thorough and detailed assessment of transfer pricing risk is essential as a first step before case teams can consider whether or not to open an enquiry. Guidance about transfer pricing case selection can be found at INTM482000 onwards.


Transfer pricing enquiries are subject to a mandatory governance process, which is explained in a separate section at INTM481000 onwards.

All enquiries into company tax returns are subject to the CTSA rules on the opening and conduct of enquiries and the ‘enquiry window’, which are contained in FA98/SCH18 for enquiries into company tax returns and TMA70/S9A or TMA70/S12AC for enquiries into other tax returns.

General guidance on the conduct of enquiries is given in the Enquiry Manual (HMRC website).

Importance of co-operative working

Experience has shown that cases are likely to be resolved earlier when a cooperative relationship based on mutual trust and respect is established from the outset. All parties should accept a share of responsibility for making progress. Case teams should seek to establish such a relationship wherever possible.

Other guidance


  • INTM480540 and INTM480550 for guidance on real time working
  • INTM483020 onwards for practical guidance on working a transfer pricing case
  • INTM480530 for guidance on how to respond if a business asks for advice or comfort about how to operate the transfer pricing rules.