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HMRC recently released its 2016/17 statistics in relation to transfer pricing and diverted profits tax. In the years from 2011/12 to 2016/17, HMRC secured £5.914 billion of additional tax by challenging the transfer pricing arrangements of multinationals. DPT was first applied in 15/16. The statistics show that prior to this year, interactions (through enquiries and settlements etc) with HMRC were shortening in duration and that there was increased appetite in proactively engaging with HMRC (through APAs and ACTAs). However, since then, the opposite has occurred, with interaction times increasing and applications for engaging with HMRC have dropped.

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