Updates to HMRC's International Manual

Within the past month HMRC has released a number of updates to its International Manual. In among the changes are some interesting insights into HMRC working practices and ‘customer friendly’ initiatives.

Importantly, HMRC provides clarification of the level of certainty that taxpayers can obtain from real time working in relation to their transfer pricing policies. The only way for legal certainty that HMRC will accept the arm’s-length price of a transaction is through an Advance Pricing Agreement. However, HMRC will now be prepared to provide a ‘general opinion’ about a transfer pricing methodology as part of real time working.