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How the UK’s new approach to transfer pricing will work

September 02, 2008

Richard Coombes of Deloitte says taxpayers should take control of HMRC’s transfer pricing process

Following a period of consultation, HMRC has confirmed and moved forward with significant changes in its approach to the handling of transfer pricing issues. The new regime introduces changes in the whole process, from risk assessment right through to settlement. It was introduced on April 1 2008, and in June this year HMRC published guidelines on how it is to work. Although the guidance is called ‘Guidelines for the conduct of transfer pricing enquiries’, it makes some important points on risk assessment and highlights just how important that phase has become in HMRC’s thinking.

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