Resolving transfer pricing disputes

SPEED READ After ten years of false starts, HMRC finally seems positioned to pursue a wide range of transfer pricing enquiries. It has the resource to do this, much of that resource has been released from the first ‘wave’ of major disputes, and case-law and changes to the OECD guidelines will encourage HMRC to think that this a fruitful area to pursue. Resolving transfer-pricing disputes requires clear technical TP analysis. But enquiries are conducted by HMRC officers, under the same pressures as other HMRC officers, and acting in the same regulatory framework. Disputes will typically be best resolved by a combination of that analysis, and a clear strategy for dealing with HMRC.