INTM451000 - Transfer pricing: governance structure and processes: Transforming Transfer Pricing Project

A new approach to transfer pricing work

The Review of Links with Large Business (ROLLB) identified that a major concern of the large business customers of HM Revenue & Customs was the impact of transfer pricing enquiries on their business. It was also clear to HM Revenue & Customs that transfer pricing was one of the highest risks to the UK corporation tax base.

In 2007 the cross-directorate Transforming Transfer Pricing Project was set up with the objective of changing radically the way that HM Revenue & Customs carried out transfer pricing enquiries to meet the recommendations of ROLLB Proposal 5 and to handle the tax risk more effectively.

The outcome of the Project was to bring in, with effect from 1 April 2008, new governance for the selection, working and settlement of transfer pricing cases. This involved

• a different structure - the Transfer Pricing Group
• new procedures

which were intended to deliver greater consistency and faster resolution of transfer pricing enquiries.