Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.
Official statistics published this week on HMRC’s transfer pricing and diverted profits tax (DPT) activity show that HMRC’s increasing international focus has been effective in achieving its intended results. The statistics highlight the sustained increase in the risks faced by multinational corporate groups dealing with the complex and ever changing international tax environment.
Tax Journal commentaries on the UK's 'deeply political tax'.
Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) examine some common misconceptions regarding DPT and highlight important points for taxpayers to consider.
Rupert Shiers and Graham Poole (Hogan Lovells) review the likely areas for disputes in the coming year.
Michael Thomas (Pump Court Tax Chambers) looks at the rules introduced in the recent Budget intended to ensure that profits from a trade dealing in or developing UK land are always chargeable to UK corporation tax or income tax.
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