HMRC’s new transfer pricing guidance on risk and reward

New transfer pricing guidance issued by HMRC reinforces the importance of granular analysis of control of economically significant risks when designing and documenting transfer pricing policies for UK entities. When contractual risk allocation is respected under the accurately delineated transaction, the new guidance emphasises that all contributions to control of economically significant risks need pricing and may participate in upside and downside outcomes arising from the playing out of the relevant risks. The guidance states that in cases where key risks are managed through highly integrated control activities, a profit split method may be appropriate.