INTM453010 - Transfer pricing: governance structure and processes: Governance process for transfer pricing enquiries: Introduction

Proposal 5 of the Review of Links with Large Business committed HMRC to resolving new transfer pricing enquiries within

• 18 months for the large majority of cases, and
• 36 months for those which are particularly complex and high risk

The Transforming Transfer Pricing Project determined that the best way to ensure that - and to deliver a performance shift in the effectiveness and consistency with which transfer pricing enquiries were worked - was to develop not only a different structure but also entirely new governance procedures.

The central plank of these procedures is the governance process to which all active and potential transfer pricing enquiries are subject.

A transfer pricing enquiry must not in any circumstances be opened (or any approach made to a customer that might be construed as a transfer pricing enquiry) or settled unless approval to do so has been obtained from the Transfer Pricing Panels or Transfer Pricing Board under the appropriate governance procedure.