The profit diversion compliance facility: a welcome opportunity or a trap to be avoided?

HMRC announced details of the new diverted profit tax/transfer pricing disclosure facility on 10 January. Whilst some may be concerned about “putting their heads above the parapet” or spending time and money to give HMRC a much more detailed and supported transfer pricing report only for it to be rejected, the indications are that HMRC want to make the facility work and to give taxpayers the opportunity to take control over the way supporting TP information is gathered. Many will welcome this initiative as a potential way of getting a TP resolution or certainty, doing so more quickly and easily by controlling the initial process and dealing with a more senior and experienced HMRC team.

This article was first published in the 18 January 2019 edition of Tax Journal.