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.Read more
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.
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.
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.
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.
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.
We investigate some of the common offshore tax misconceptions for UK resident and domiciled individuals and how to avoid them.
We investigate some of the common offshore tax misconceptions for UK resident and non-UK domiciled individuals and how to avoid them.
13 May 2017
It has been five years since George Osborne and his G7 counterparts kick-started the overhaul of the international tax system, leading to the OECD’s base erosion and profit shifting (BEPS) action plan. Companies that are part of multinational groups now need to take action to comply with updated UK legislation concerning perhaps the most far reaching consequence of BEPS – country by country (CbC) reporting
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.