His Majesty's Revenue & Customs (HMRC) published new operational guidance for transfer pricing that sets out its view on the application of the OECD's six-step process for analyzing risk. The OECD’s process addresses the identification of economically significant risks, control of risks, role of contracts and pricing of transactions taking into account the arm's-length risk allocation. An EY Tax Alert outlines the six-step process and discusses some of the key concerns around risk management…
EYEY Global Tax Controversy Flash Newsletter (Issue 70) | UK releases new operational guidance on effective risk management in transfer pricing transactions
