The Review promised the introduction, by 31 December 2007, of a more efficient approach to undertaking transfer pricing enquiries. A greater focus on high risk businesses and transactions would mean that enquiries for businesses with less complex affairs would be resolved more quickly.
Those with complex transfer pricing issues would also have the opportunity to benefit from swifter resolution and would have more certainty as to how and when matters would be concluded.
The Review envisaged that, where businesses promptly provided the information needed for an enquiry, transfer pricing enquiries should normally be completed within 18 months. It was recognised that some enquiries that were both particularly complex and high risk might take longer even where businesses made full and transparent disclosure of supporting facts and commercial intent and promptly provided information. It was expected that these enquiries would take no longer than 36 months to resolution or the point where preparation for litigation started.
