HMRC Powers

Steve Hasson and Ray McCann from PricewaterhouseCoopers LLP look at HMRC's new approach to transfer pricing enquiries and consider the impact of the new regime

In the past two years there has been much interest on the international scene and significant changes in HMRC's approach are already having an impact on corporate clients. These have included major changes in how HMRC organises and controls transfer pricing enquiries as well as a new approach to treaty clearances and thin capitalisation (including the introduction of advance thin capitalisation agreements). HMRC also appears to be much more active in exchanging information with overseas tax authorities and its use of TMA...