HMRC Guidance: A New Transfer Pricing Risk to Control

Transfer pricing does not get much more complex than the control of risk framework — which different tax authorities interpret in different ways. But the punchline of new guidance, published by HMRC is simple: where businesses have senior personnel in the UK and those personnel are responsible for making decisions about key business risks, they should be thinking about what implications recent HMRC guidance has for their transfer pricing policies.

Background

In January 2024, HMRC — the UK’s tax authority — released guidance on their approach to applying the 6-step process for analyzing risks that has been part of the ...