KPMG report: HMRC guidance on OECD’s control of risk framework

Implications that HMRC guidance has for transfer pricing policies

Implications that HMRC guidance has for transfer pricing policies

Transfer pricing does not get much more complex than the OECD’s control of risk framework—which different tax authorities interpret in different ways. But the punchline of new guidance from the HMRC clarifying their interpretation of the framework is simple: when businesses have senior personnel in the UK and those personnel are responsible for making decisions about key business risks, they need to think about what implications that HMRC guidance has for their transfer pricing policies.

Read a February 2024 report* [PDF 213 KB] prepared by KPMG professionals: HMRC Guidance: A New Transfer Pricing Risk to Control

* Reproduced with permission from Tax Management International Journal, 1/30/2024. Copyright @ 2024 by Bloomberg Industry Group, Inc. (800-372-1033)



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