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The United Kingdom (UK) Tax Authority (Her Majesty’s Revenue and Customs or HMRC) has introduced a number of different approaches to address what it sees as shortcomings in the application of the arm’s-length principle by some taxpayers. This initiative has resulted in a series of guidelines and compliance processes for multinational entities (MNEs) with a UK presence, including the Diverted Profits Project (DPP), which seeks to minimize profit diversion arrangements by MNEs.

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