UK HMRC has updated its transfer pricing operational guidance with a new section on the accurate delineation of actual transactions and the analysis of risk.
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Scope of this guidance
1. This guidance addresses HMRC's application of the '6-step process for analysing risk' ('the 6-step process') within Chapter I of the OECD Transfer Pricing Guidelines ('TPG').
2. The significance of risk in a transfer pricing analysis has been a subject of debate amongst commentators following the 2017…