The amount of ‘tax under consideration’ by HMRC’s large business directorate has increased by 60% in the last year, to £3.8bn, according to Pinsent Masons. This is an estimate of the amount potentially at stake across all open enquiries involving the largest companies.
The amount of ‘tax under consideration’ by HMRC’s large business directorate has increased by 60% in the last year, to £3.8bn, according to Pinsent Masons. This is an estimate of the amount potentially at stake across all open enquiries involving the largest companies.
Heather Self, tax partner at Pinsent Masons, said: ‘It seems the Revenue is taking a fresh look at the UK's largest businesses, with a focus on intra-group, cross-border transactions. This is likely to be a reaction to the increasing focus of the OECD and EU on international taxation, and it suggests that HMRC is getting bolder at challenging the amount of profit which should be allocated to UK economic activities.’
The diverted profits tax could be one of the factors driving the increase in the amounts of tax under consideration. Self said: ‘Although it is too early to see DPT enquiries, we could be seeing a surge in transfer pricing challenges for earlier years, with a view to extending them to DPT later on.’
The amount of ‘tax under consideration’ by HMRC’s large business directorate has increased by 60% in the last year, to £3.8bn, according to Pinsent Masons. This is an estimate of the amount potentially at stake across all open enquiries involving the largest companies.
The amount of ‘tax under consideration’ by HMRC’s large business directorate has increased by 60% in the last year, to £3.8bn, according to Pinsent Masons. This is an estimate of the amount potentially at stake across all open enquiries involving the largest companies.
Heather Self, tax partner at Pinsent Masons, said: ‘It seems the Revenue is taking a fresh look at the UK's largest businesses, with a focus on intra-group, cross-border transactions. This is likely to be a reaction to the increasing focus of the OECD and EU on international taxation, and it suggests that HMRC is getting bolder at challenging the amount of profit which should be allocated to UK economic activities.’
The diverted profits tax could be one of the factors driving the increase in the amounts of tax under consideration. Self said: ‘Although it is too early to see DPT enquiries, we could be seeing a surge in transfer pricing challenges for earlier years, with a view to extending them to DPT later on.’
