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HMRC internal manual

International Manual

Transfer pricing operational guidance: Evidence gathering: General research

Range of sources

A range of print and online sources is available with up to date information on what is happening in any industry sector - merger and acquisition activity, new products, licences granted, collaboration agreements entered into, joint ventures undertaken.

The business pages of UK and overseas newspapers can yield useful information. For instance it may give some idea of the type of brands and products that are licensed between independent parties and sometimes the royalty rate payable under such an agreement. Be aware though that such information may be speculative and probably incomplete. In itself, such information is not a comparable, but it can help to give some perspective on a case.

Large Business Service sector teams and Trade Sector advisers may have access to information about their sector or may be able to suggest avenues for case teams to research.

Useful data is also available from commercial information providers about licence agreements that are entered into by independent parties. Case teams are unlikely to find a direct comparable. And the information is likely to be incomplete - however good the information provider may be, they won’t receive access to all the details surrounding a licence transaction. They may however provide general information which might help indicate whether the case team’s work on trying to establish an arm’s length price is reasonable. The absence of any information on the type of licence agreements or business transactions for which comparisons are being sought might suggest that the intra-group transactions at issue do not happen in the commercial world between independent parties.

Case teams in need of further advice should discuss the case with their TP Specialist.