Where a penalty is imposed with regard to a transfer pricing matter, it will be imposed under the rules applying generally; there are no special rules applying in this regard. For commentary on the penalty regime applying where a document submitted to HMRC contains an inaccuracy, and on the failure to keep and preserve records, see ¶181-900ff.

As it is acknowledged that transfer pricing is not an exact science, HMRC adopt a different approach when imposing penalties in transfer pricing cases than is usually the case, and in particular with regard to negligent or careless conduct (see INTM 483110/483120). Taxpayers can take comfort from the following statement:

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