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New disclosure facility to tackle the diversion of profits away from the UK

16 February 2019

HMRC believes some multi-national enterprises have cross border arrangements in place which are not consistent with the OECD’s transfer pricing guidelines, that result in the diversion of profits away from the UK such that profits are taxed at lower rates or not at all. These types of arrangements are targeted by transfer pricing rules, together with the diverted profits tax (DPT) legislation, effective from 1 April 2015.

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New disclosure facility opened by HMRC to tackle the diversion of profits away from the UK
Andrew Hinsley

11 January 2019

HMRC believes some multi-national enterprises have cross border arrangements in place which are not consistent with the Organisation for Economic Co-operation and Development’s (OECD) transfer pricing guidelines, that result in the diversion of profits away from the UK such that profits are taxed at lower rates or not at all. These types of arrangements are targeted by the diverted profits tax (DPT) legislation, effective from 1 April 2015.

Requirement to correct – Time is running out

03 September 2018

HMRC has recently updated its guidance regarding the deadline for notifications under the requirement to correct (RTC) rules. As a reminder, RTC creates an obligation for anyone who has undeclared UK tax liabilities that involve offshore matters or transfers to disclose this non-compliance to HMRC by 30 September 2018. This includes inheritance tax on assets owned by non-UK entities.

Is naming and shaming tax defaulters an effective tax evasion deterrent?

24 August 2018

Being ‘named and shamed’ as a tax evader presents a serious reputational and financial risk. But do taxpayers see this as a deterrent? And do they know the risks?

Requirement to correct – It’s not too late
Andrew Hinsley

30 July 2018

HMRC guidance regarding its requirement to correct (RTC) has been updated. So long as HMRC has been notified of a taxpayer’s intention to disclose by 30 September 2018 using its online worldwide disclosure facility (WDF), the taxpayer will be considered to have met the deadline.

How good is your tax risk governance evidence?

18 May 2018

The outcomes from HMRC’s recent consultation on its Business Risk Review (BRR) process should enable large businesses to positively influence their risk rating, providing they have the evidence to support robust tax risk management processes.

Increased HMRC focus on offshore property for developers

04 April 2018

Are your clients at risk of an investigation by the Offshore Property Developers Task Force (OPDTF)?

HMRC's targeting of EIS investors could damage the growth of the UK economy

09 February 2018

HMRC appears concerned about perceived abuse of the enterprise investment scheme (EIS) tax reliefs available to individuals. It is undertaking a data-mining programme, using profiling, to open detailed formal tax enquiries into the personal tax affairs of investors, principally to gather data.

HMRC urgently needs to clarify penalty policy

11 January 2018

HMRC has recently revised its penalty factsheet which appears to impose new penalty arrangements for those wishing to correct historic tax errors. There is an urgent need for HMRC to clarify exactly what the policy now is and to confirm its legal basis.

When is a van not a van? When it’s a car

13 September 2017

A recent First Tier Tax Tribunal decision leaves many employees facing heavy tax bills on company cars that they thought were vans. Employers will need to consider settling the bills on their behalf to avoid having disgruntled employees. The Tribunal gave some useful guidelines on the distinction between a van and a car, but the position remains hopelessly unclear, especially with misleading HMRC guidance.

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