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Fortnight to 9 August 2018

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK.

Latest Transfer Pricing and DPT statistics from HMRC
HMRC has just released its latest statistics on transfer pricing and Diverted Profits Tax (DPT). In the 6 years to 2017/18, HMRC recorded some £6.5 billion of additional tax by challenging transfer pricing arrangements, with the yield in 2017/18 approaching £1.7 billion. DPT, now in its third year, produced a separate yield of £388 million and the number of DPT notifications has risen to 220. The other significant change is the dramatic fall in Advance Pricing Agreement (APA) applications, which fell to 16 in 2017/18, half the previous year, coupled with an increase in the number of requests for the Mutual Assistance Procedure (MAP) which have more than doubled over the last 6 years.

Corporate Governance: Time to act
Following the recent adoption of the new Corporate Governance reporting regulations extending sustainable and responsible governance practices to U.K. private limited companies, those businesses will need to quickly assess their corporate governance framework and reporting to be compliant from 1 January 2019.

HMRC late payment interest rates to rise
HMRC is to raise its interest rates for corporation tax quarterly instalments paid late from 13 August 2018 and for other taxes and duties from 21 August 2018, following the Bank of England’s announcement of a rise in the base rate. The new rates will be announced shortly. See this HMRC news story.