His Majesty's Revenue & Customs (HMRC) published new operational guidance for transfer pricing that sets out its view on the application of the OECD's six-step process for analyzing risk. The OECD’s process addresses the identification of economically significant risks, control of risks, role of contracts and pricing of transactions taking into account the arm's-length risk allocation. An EY Tax Alert outlines the six-step process and discusses some of the key concerns around risk management and control being raised by HMRC in transfer pricing enquiries and other engagements with taxpayers.Considering this guidance, businesses should review their economically significant risks to determine...