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Contentious tax: quarterly review

Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

A taxing time for multinationals

HMRC estimates that the 2 000 largest businesses with operations in the UK may owe an additional £34.8bn in tax relating to the 2019/20 financial year — up from £29.9bn in 2018/19. A recent letter sent by HMRC to multinationals asks companies how confident they are that their transfer pricing is ‘appropriate’. HMRC has directed companies to submit information about their transfer pricing arrangements to its profit diversion compliance facility within 90 days or face further investigation. The letter states amongst other things:

‘In investigations we have carried out to date we are often finding that the UK profits do not reflect the value created in the UK … We are also finding indications of careless or deliberate behaviour requiring penalties to be considered ... It will be too...

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