Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
HMRC enquiries can be long-drawn-out affairs. According to HMRC’s published statistics it takes on average nearly three years to resolve a typical transfer pricing (TP) enquiry. Concern about taxpayers digging in their heels and unreasonably drawing out the enquiry process was part of the rationale for introducing diverted profits tax (DPT) in 2015. It is perhaps ironic therefore that taxpayers under enquiry now worry about delay or intransigence on HMRC’s part leading to forced concessions under the accelerated DPT timetable. This article explains the procedural parameters within which companies must now navigate the resolution of TP and DPT enquiries and it highlights potential pitfalls of which advisers should be aware.
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Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
HMRC enquiries can be long-drawn-out affairs. According to HMRC’s published statistics it takes on average nearly three years to resolve a typical transfer pricing (TP) enquiry. Concern about taxpayers digging in their heels and unreasonably drawing out the enquiry process was part of the rationale for introducing diverted profits tax (DPT) in 2015. It is perhaps ironic therefore that taxpayers under enquiry now worry about delay or intransigence on HMRC’s part leading to forced concessions under the accelerated DPT timetable. This article explains the procedural parameters within which companies must now navigate the resolution of TP and DPT enquiries and it highlights potential pitfalls of which advisers should be aware.
In my beginning is my end
How an enquiry ends...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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