Expert Reviewer - Transfer pricing elements of Operational Separation

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The purpose of the Financial Reporting Council (FRC) is to serve the public interest by setting high standards of corporate governance, reporting and audit and by holding to account those responsible for delivering them.

In February 2021, the FRC published the revised Operational Separation Objectives, Outcomes and Principles (the 'Principles'). Through Operational Separation, we intend to: i) Improve audit quality by ensuring that people in the audit practice are focused above all on delivery of high-quality audits in the public interest. ii) Improve audit market resilience by ensuring that no material, structural cross-subsidy persists between the audit practice and the rest of the firm.

The revised principles for operational separation of the audit practices have voluntarily been adopted by the largest four audit firms in the UK. The objective of operational separation is to ensure that audit practices are focused above all on delivery of high-quality audits in the public interest, and to improve audit market resilience by ensuring that there is no subsidy between the audit practice and the other service lines.

Through the principles the FRC limits the scope of service that can be delivered by firms' audit practices mainly to undertaking statutory audits and related work. However, to deliver on a statutory audit especially for large and complex audited entities, the audit practice will need expertise which may not necessarily be located within the audit practice but may have to be borrowed from the other service lines in the firm for example: actuaries, valuers, IT specialists etc. In accordance with the Principles, we would expect the firms to charge these expert resources at arms' length prices (similarly if auditors work on engagements/ projects in other service lines then they would also need to be charged at an arm's length price). This will ensure that there is no subsidy between the audit practice and the other parts of the firm, and thus that audits are priced to reflect the economic reality.

The aim of this project was to engage an Expert Reviewer on transfer pricing, who will review the four largest audit firm's transfer pricing methodologies and policies for operational separation.

The transfer pricing expert should undertake a design effectiveness review of the transfer pricing methodology and policies used by the four largest audit firms in implementing the Operational Separation Principle on arm's length pricing.

The report should detail: 1. For each firm, the appropriateness of and the risks and issues arising from the firms' methodologies and policies for transfer pricing. 2. A comparison between the firms' arm's length pricing methodologies and policies to form a view as to whether, overall, there is a level playing field, given the firms' differences in approach. 3. An opinion on whether there is any potential for improvement, and related recommendations.

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Additional information: THIS IS A CONTRACT AWARD NOTICE. THIS TENDER HAS BEEN COMPLETED.