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Two weeks to 14 August 2019

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

This is not just Transfer Pricing - this is Profit Diversion
Increasingly, businesses are discovering that transfer pricing enquiries are more likely to be part of a much wider investigation by HMRC into ‘profit diversion’. This type of investigation may start following a Diverted Profits Tax notification, but can be very wide-ranging covering a range of cross-border issues from company residence to hybrids, but will usually be resolved through an adjustment to the transfer pricing. Another feature of these investigations is that they are highly forensic in nature and large amounts of evidence will be requested from interviews of senior people to reviews of emails. Read more.

HMRC Powers and Taxpayer safeguards
In a recent written ministerial statement, Jesse Norman (Financial Secretary to the Treasury) announced a number of actions being taken by HMRC following the issue of the House of Lords Economic Affairs Committee report entitled ‘HMRC Powers: Treating taxpayers fairly’. Further updates will be provided to the Committee later in the year. Read more.

Double tax treaty updates: