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A new disclosure
Key points
- A new profit diversion compliance facility for multinationals within the scope of the diverted profits tax and transfer pricing rules.
- The aim is to encourage compliance by changing behaviours or filing a detailed disclosure report.
- Incentives to disclose include a reduced penalty charge and avoiding an enquiry.
- HMRC will issue letters to some businesses identified as high risk.
- Given the complexity and potential risks many businesses will need to review their position and take action accordingly.
For multinationals within the scope of the diverted profits tax and transfer pricing rules Ken Almand explains the thinking behind HMRC’s new profit diversion compliance facility.
Tax professionals might be forgiven for becoming rather weary of the compliance burden relating to cross-border tax issues. Diverted profits tax (DPT) corporate interest and anti-hybrid rules have all been introduced in recent years and the transfer pricing principles have been overhauled by the base erosion profit shifting (BEPS) programme...
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