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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.

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.

Criminal Finances Act 2017
Carolyn Brown

11 September 2017

From September 2017 new UK legislation - the Criminal Finances Act 2017 - requires that incorporated bodies (usually companies) and partnerships must act to prevent potential criminal facilitation of tax evasion by persons associated with them.

Common offshore tax misconceptions of UK resident and domiciled individuals
Andrew Hinsley

We investigate some of the common offshore tax misconceptions for UK resident and domiciled individuals and how to avoid them.

Common offshore tax misconceptions of UK resident and non-UK domiciled individuals
Andrew Hinsley

We investigate some of the common offshore tax misconceptions for UK resident and non-UK domiciled individuals and how to avoid them.

HMRC's consultation on risk profiling - what can it add?

18 April 2017

In the Spring Budget 2017 it was announced that HMRC will consult over the summer on its process for risk profiling large businesses. HMRC’s policy is to match its resource to perceived tax risk, so risk profiling is a key element of its strategy.

The requirement to correct - offshore tax matters
Andrew Hinsley

29 March 2017

On 5 December 2016, HMRC published draft ‘requirement to correct’ (RTC) legislation. With effect from 6 April 2017, those who do not put their off shore tax affairs in order by 30 September 2018 will be subject to significantly increased penalties.

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