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 transfer pricing, the diverted profits tax, and other relevant areas of UK tax. This could include permanent establishment, WHT, CFCs, hybrid mismatch rules, and corporate residence.
Please see full Publication below for more information.