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How to handle transfer pricing discovery assessments

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Despite HMRC updating its guidance to put beyond doubt that ‘protective’ discovery assessments should not be raised, in practice such assessments often appear to be raised in relation to transfer pricing matters. These should include an explanation of why the provision entered into by the taxpayer was not arm’s length, as well as determination of HMRC’s view of the arm’s length provision. Following receipt of such an assessment, the options are broadly to settle, appeal or (assuming it relates to a transaction with a counterparty in a treaty jurisdiction) refer the discovery assessment to the competent authority for resolution.

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