Arcotia Hatsidimitris - International Tax Dialogue

7. RESOURCES, SKILLS AND USE OF SPECIALISTS – 61
• The transfer pricing units assist the case teams responsible for the tax compliance of a particular
business in:
assessing the transfer pricing risk
where appropriate, making a report to the relevant transfer pricing panel recommending that an
enquiry be undertaken into the transfer pricing of the business
assisting in the subsequent enquiry
• The transfer pricing panels approve operational decisions as to:
whether to open a transfer pricing enquiry
how a transfer pricing enquiry should be settled, e.g. by negotiation or settlement
the parameters within which case teams may settle where negotiation is appropriate
• The transfer pricing board:
sets the strategic direction of the Transfer Pricing Group
approves operational decision-making on higher risk cases
• There are, additionally, three specialist units available to provide guidance and support to the case
teams and who have representation on the Panels:
Business International which has overall policy responsibility for the UK’s transfer pricing
legislation and provides specialist advice and training in respect of the application of that
legislation. It also provides support and advice in respect of the risk assessment, undertaking
and progressing of transfer pricing cases. This can include attendance at meetings with the
business and its representatives. Business International also has responsibility for the APA and
FMAP processes.
Specialist Investigations which provides experience in document examination, interviewing of
personnel, negotiation and litigation.
Knowledge, Analysis and Intelligence which provides specialist input from economists when necessary.
Many tax administrations found that a structural model which includes some form of
centralisation or specialisation can assist in providing more effective and efficient training to staff and
in maintaining and developing knowledge management. The training needs of a smaller group can be
more carefully identified and more easily and cheaply met. In addition some tax administrations have
developed new ways to deliver training that retain the face to face element but reduce the need for
travel costs.
In the US the Internal Revenue Service (IRS) has recently reorganised its international work.
International examiners and economists will continue to work with colleagues in the field as members
of a broader team but they are now managed as a cohort of specialists. There were a number of drivers
behind the change. In part it was a response to the growing importance and complexity of international
issues and transfer pricing in particular that was discussed in the introduction. The advisory firms that
the IRS deals with commonly have specialist teams dealing with international issues and the IRS
needs to match their levels of experience and expertise. Creating a national team of international
specialists also makes it easier to deploy resources where they are most needed. This was harder when
specialists were part of regionally defined teams as transfer pricing risks are not evenly distributed
across the country. And improving the training and development of international examiners and
economists is another key objective for the new organisation.
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012