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HMRC internal manual

International Manual

Transfer pricing: operational guidance: examining transfer pricing reports: report contents

Likely structure

  • Functional analysis
  • Reviewed transactions
  • Legislation
  • OECD methodologies reviewed
  • Most appropriate methodology selected
  • Appropriate methodology applied
  • Selection of ‘comparable’ companies or transactions
  • Arm’s length range of results
  • Consideration of where the tested party’s results are in the range
  • Conclusion

The key components above are examined in more detail at INTM484030 onwards. Case teams should not however assume that any one of the above components, either as it appears in the report itself or in this guidance, is conclusive. Rather the report should be considered as a whole. What does it say about the company and are its conclusions valid? A report is not necessarily incomplete if not all the possible component areas are present. The most useful reports provide detailed functional analysis. A report lacking in such detail is unlikely to be of any value.