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As you may have seen, earlier this year, HMRC released updated operational guidance on transfer pricing and the role of risk which seeks to codify HMRC’s views on the topic. The UK EY team has been meeting with a number of clients to discuss how HMRC’s operational guidance on the OECD’s six-step analysis of risk (published in the International Manual) will impact MNE groups, informed by our practical experience in HMRC enquiries of how the guidance is being applied. Our transfer pricing team has developed a new offering for clients enabling them to assess the robustness of their analysis and documentation of economically significant risks (ESRs) and risk control functions. The EY ESR Assessment is a structured analysis giving clients a clear assessment of their position and prioritised recommendations to address areas of potential challenge. For further information, please reach out to me or your EY UK contact.
As you may have seen, earlier this year, HMRC released updated operational guidance on transfer pricing and the role of risk which seeks to codify HMRC’s views on the topic. The UK EY team has been meeting with a number of clients to discuss how HMRC’s operational guidance on the OECD’s six-step analysis of risk (published in the International Manual) will impact MNE groups, informed by our practical experience in HMRC enquiries of how the guidance is being applied. Our transfer pricing team has developed a new offering for clients enabling them to assess the robustness of their analysis and documentation of economically significant risks (ESRs) and risk control functions. The EY ESR Assessment is a structured analysis giving clients a clear assessment of their position and prioritised recommendations to address areas of potential challenge. For further information, please reach out to me or your EY UK contact.