NERA hosted a European American Tax Institute roundtable discussion in our London office on 16 October 2008. The discussion, which included NERA Special Consultant Pim Fris, examined implications of the significant people functions concept for transfer pricing. The concept was introduced by the OECD's report on the attribution of profits to permanent establishments. Representatives of Her Majesty's Revenue and Customs (HMRC) -- Rick Clayton, an international specialist with the International Financial Services group, and Andrew Martyn, Group Leader, Investment Management and International Financial Services -- shared HMRC's views on this topic.