Handling HMRC Transfer Pricing Enquiries - A Practical Guide

Introduction

Transfer pricing remains an important area of HMRC scrutiny, and the increasing availability of structured information on multinational groups and their related-party transactions gives HMRC greater ability to identify and investigate potential transfer pricing risks.

When an enquiry begins, businesses and their advisers need to understand what HMRC is looking for, how to respond effectively and how decisions made at the beginning of an enquiry can influence its eventual outcome.

This new live and interactive session will take you through the lifecycle of a transfer pricing enquiry, from the initial HMRC approach through information gathering, technical challenge and resolution.

Using practical examples, expert speaker Rafaela Oplopoiou-Chapman will help you identify common areas of difficulty and develop a structured approach to managing an HMRC transfer pricing enquiry.

What You Will Learn

This live and interactive session will cover the following:

• How transfer pricing enquiries arise:
• HMRC's transfer pricing risk assessment
• Common enquiry triggers and risk indicators
• Transactions likely to attract scrutiny
• Role of transfer pricing documentation
• The impact of increased data and reporting
• The opening of an enquiry:
• Understanding HMRC's initial concerns
• Initial information and documentation requests
• Establishing the facts and controlling the enquiry process
• Internal stakeholders and responsibilities
• Working effectively with advisers
• Responding to HMRC:
• Managing information requests
• Reviewing the functional analysis
• Supporting the selected transfer pricing method
• Benchmarking and comparables
• Evidence supporting the commercial rationale
• Dealing with inconsistencies in documentation
• Common mistakes when responding to HMRC
• Managing technical challenges
• Challenges to functions, assets and risks
• Challenges to entity characterisation
• Pricing methodology disputes
• Financial transactions and other common areas of challenge
• Documentation prepared after the event
• Maintaining a defensible audit trail
• Penalties, resolution and dispute management
• Transfer pricing adjustments
• Penalty considerations and reasonable care
• Managing negotiations with HMRC
• Advance Pricing Agreements
• Mutual Agreement Procedure
• When disputes become international
• Practical case study

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.