In applying the UK’s transfer pricing rules, tax advisers have to think beyond the amount of the debt and the interest rate to get comfortable that an intra-group loan is going to be tax deductible. Following a recent case,...more
When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more
HMRC have announced that it will be holding a webinar on Tuesday 6 October to provide an update on its Profit Diversion Compliance Facility (PDCF). The facility is a mechanism that multinational firms can use to settle...more
What is the Profit Diversion Compliance Facility?
What the PDCF does -
The facility is a mechanism that multinational firms can use to settle potential tax liabilities for past years that remain open. It relates to...more
We recently had the opportunity to hear HMRC's latest views on valuing growth shares for UK tax purposes.
We consider below the importance of share valuation in general and provide an update on HMRC's approach to valuing...more
The UK tax authority, HMRC, recently announced the introduction of a new Profit Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by diverting profits outside the UK without proper economic...more
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more
HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch...more