INTM453080 - Transfer pricing: governance structure and processes: Governance process for transfer pricing legacy enquiries: Legacy Cases

The transfer pricing governance procedures apply to all new potential transfer pricing enquiries after 1 April 2008.

The transfer pricing procedures also apply (as far as they can) to any transfer pricing enquiries underway at that time: so-called legacy cases.

All legacy cases have been assigned a Transfer Pricing Specialist and are required to have an Action Plan in place unless they already have something which is equivalent. The cases are then subject to full progress and resolution review procedures.

Legacy cases are not subject to the 18/36 month deadlines but should be progressed to resolution review as soon as possible in accordance with the spirit of Review of Links with Large Business, Proposal 5.