The UK tax office updated its international manual on transfer pricing to clarify its view on risk factors in the “accurate delineation” of transactions.
His Majesty’s Revenue and Customs added a new page to its transfer pricing operational guidance about risk, addressing what the office acknowledged has been a subject of debate since 2017 and later updates to the guidance.
The new material clarifies HMRC’s approach to identifying economically significant risks, ways of controlling risk, the role of contracts and pricing transactions, and taking into account risk allocation. “This does not reflect any change in ...
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