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Transfer pricing: The rising risks and costs of non-compliance

Transfer pricing: The rising risks and costs of non-com

The cost of getting transfer pricing wrong is rising for taxpayers as HMRC continue to target profit diversion.


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Transfer pricing is high on groups’ lists of major tax risks. Buoyed by their recent success in more than doubling their take from transfer pricing and diverted profits tax investigations, HMRC launched a Profit Diversion Compliance Facility (PDCF) in January 2019. In doing so they have put Multi-National Enterprises on notice that they see widespread non-compliance with BEPS in their cross-border arrangements.

In this article, Phil Roper and Tania Dimitrovich-Archer, look at:

  • HMRC’s increased scrutiny on the pricing of transactions between group companies, including the launch of the PDCF;
  • The evidence required to support transfer pricing methodology;
  • The increased rigour by HMRC in enforcing the penalty regime; and
  • Other issues including the reduction of penalties for disclosure and the suspension of penalties.

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