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Significant changes to UK transfer pricing guidelines

HMRC has made significant changes to the transfer pricing sections of the Inland Revenue Manuals.

Several changes, published August 9, have been made to the existing guidance; new sections have been added, and old sections removed or reworded. HMRC have sought to restructure the chapters into a more user friendly format and provide additional guidance.

This rewrite is welcome as it should help UK taxpayers’ understanding of HMRC's requirements for transfer pricing and how their transactions and documentation may be audited as part of a risk management review or enquiry.

Further commentary on the changes and the new chapters are to follow from principal TPWeek correspondents for the UK, Grant Thornton. (

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