HMRC’s recently published statistics for TP/DPT covering 1 April 2018 to 31 March 2019 confirm that tackling profit diversion remains a priority area for HMRC.
The key takeaways from the recent statistics are:
Transfer pricing yield has fallen from the recent peak, matching the longer term average
Most DPT cases are settling by transfer pricing adjustments (when DPT paid on Charging Notices is repaid)
HMRC taking longer to settle old TP enquiries