Episode 104: Who bears the risk? Navigating HMRC’s guidance

Overview

In this episode of TP Talks, Kristina Novak (Principal in PwC’s US National Tax Services Transfer Pricing practice) sits down with Ian Dykes (Transfer Pricing Partner and Global Disputes Leader with PwC UK) to discuss the recent guidance issued by HMRC (His Majesty's Revenue and Customs) on identifying and pricing contributions to risk control by decision-makers. They delve into the purpose of this new guidance, its implications for taxpayers, and the challenges it presents. They also explore the interaction between HMRC's concept of risk and the current transfer pricing rules, including the role of contracts and assets. The episode concludes with final takeaways and insights into the ongoing international debate on these transfer pricing issues.

See also:

PwC Tax Insight: HMRC releases important guidance on identifying and pricing contributions to risk control by decision-makers.

Contacts: Kristina Novak, Ian Dykes