Transfer pricing is high on the lists of major tax risks for UK taxpayers.
HM Revenue & Customs (HMRC), buoyed by recent success in more than doubling the take from transfer pricing and diverted profits tax investigations, in January 2019 launched a profit diversion compliance facility (PDCF). In doing so, HMRC put multinational enterprises (MNEs) on notice of findings of widespread non-compliance with base erosion and profit shifting (BEPS) in their cross-border arrangements.
A July 2019 report [PDF 561 KB] prepared by the KPMG member firm in the UK considers:
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