[INTM483010] Transfer pricing: operational guidance: working a transfer pricing case: opening the case
Conducting an effective case
A clear strategy from the outset is essential. Case teams should bear in mind at all times that the purpose of a transfer pricing enquiry is to test controlled transactions against the arm's length principle; see INTM412020. The team's strategy should seek to identify and focus on the main areas of risk whilst balancing input with resource available, including the time which may potentially be required if a negotiated settlement cannot be reached.