INTM452030 - Transfer Pricing: governance structure and processes: Transfer Pricing Group: Roles and responsibilities within the Transfer Pricing Group
Transfer Pricing Board
Transfer Pricing Panels
Transfer Pricing Units
Transfer Pricing Secretariat
Transfer Pricing Board
In addition to its role in setting the strategic direction for transfer pricing work, the Transfer Pricing Board has responsibility for operational decision-making on the higher risk cases. The very highest risk cases are, however, subject to input and final decision by HMRC’s Excom.
Transfer Pricing Panels
The Large Business Service (LBS) and Local Compliance (LC) Transfer Pricing Panels are the lynch-pins of the transfer pricing governance structure. They decide for cases from their respective directorates (and having due regard to the recommendation of the case teams)
- whether to open a transfer pricing enquiry or not
- how a transfer pricing enquiry should be settled, i.e. by concession, negotiation or litigation
- the parameters within which case teams may settle where negotiation is appropriate
The Panels also have a responsibility for monitoring progress on all transfer pricing enquiries at regular intervals based on the six-monthly reviews undertaken by the case teams/Transfer Pricing Specialists.
Transfer Pricing Units
There are four LC Transfer Pricing Units based in Bristol, Coventry, Leeds and London and five LBS Transfer Pricing Units located in Birmingham, Bristol/Reading, Glasgow, London and Nottingham.
Each Unit comprises 3-5 Transfer Pricing Specialists and at least one Assistant Transfer Pricing Specialist.
The role of the Transfer Pricing Specialist is to
- give transfer pricing advice to case teams on every transfer pricing enquiry
- provide a link between case teams and other directorates providing specialist guidance and support
- ensure that transfer pricing governance procedures are followed in all cases
Just how much involvement a Transfer Pricing Specialist has in a case will depend, inter alia, upon its nature and the experience of the case team. In a straightforward enquiry, it may be limited to a watching brief with the focus on adherence to governance processes whereas, at the other extreme, the case may be so complex and resource-intensive that the Transfer Pricing Specialist will work the enquiry (or aspects of it) as part of the case team, having direct involvement with the customer and, where appropriate, taking the lead in an enquiry.
The role of the Assistant Transfer Pricing Specialist is primarily to provide support to his/her Transfer Pricing Unit. At one end of the spectrum, this involves admin and systems support and research and intelligence activities whilst, at the other, he/she may assist in working particular aspects of an enquiry, e.g. records examination, systems reviews etc.
Transfer Pricing Secretariat
This unit, housed in Business International at 100 Parliament Street, provides admin support to the Transfer Pricing Board.
