HMRC Approach to Transfer Pricing for Large Business Consultation Document - ACT Response

The ACT’s view is that it recognises and appreciates the commitment of HMRC to implement a more efficient approach to undertaking transfer pricing enquiries, by 31 December 2007. In addition the ACT is aware of the need for HMRC to respond to and conform with relevant EU Directives and legislation. In general we are supportive of the proposals made by HMRC although we have some specific comments as outlined below.