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Resolving transfer pricing disputes

HMRC finally seems positioned to pursue a wide range of transfer pricing enquiries

 

 

Against a backdrop of economic downturn and lower tax receipts tax authorities around the world are fiercely fighting for their right to tax company profits. HMRC is no exception.

There is no doubt that profits can easily flow overseas. HMRC can also feel that it has done much to reduce the ‘loss of tax’ attributable to highly structured transactions exploiting loopholes in the UK corporation tax code.

These things cause an increasing perception that the biggest risk to the UK corporation tax base is for profits to be taxed not in the UK but elsewhere.

Tax directors have worried for at least ten years about HMRC finally taking transfer pricing audits more seriously. In all that time no widespread action has really materialised and there have...

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