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International issues: mitigating controversy

Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.

One of HMRC’s key strategic objectives is to bear down on tackling avoidance and evasion. HMRC’s 2019 to 2020 annual report shows that in the year to 31 March 2020 the department generated £36.9bn of additional revenue from its compliance activities.

HMRC’s report on compliance yield (Customer compliance: how HMRC’s compliance yield is split by business area and our approach to tax compliance and large businesses November 2020) states that of the £36.9bn additional revenue more than one third (£13.2bn) came from companies handled by the Large Business Directorate. This is despite the fact that the directorate monitors around only 2 000 of the 5.9m businesses operating in the UK (according to Business population...

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