Transfer Pricing:Written question - 220148

Q
(Na h-Eileanan an Iar)
Asked on: 12 February 2019
Treasury
Transfer Pricing
Commons
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of transactions under investigation; and how many inquiries resulted in the view that the factual pattern outlined to HMRC at the start of an enquiry did not stand up to scrutiny once tested in each of the last five years.
A
Answered by: Mel Stride
Answered on: 20 February 2019

On 10 January 2019 HMRC introduced a new Profit Diversion Compliance Facility for Multi-National Enterprises using arrangements targeted by the Diverted Profits Tax (DPT) to give them the opportunity to bring their UK tax affairs up to date.

HMRC does not hold the information about the value of transactions under investigation.

HMRC does not hold information about how many inquiries resulted in the view that the factual pattern outlined to HMRC at the start of an enquiry did not stand up to scrutiny once tested in each of the last five years.

However, in circumstances where HMRC believes it may have been misled by information provided by customers in the context of transfer pricing investigations, the matter will be referred to its Fraud Investigation Service.

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