When is an amnesty not an amnesty? When the carrot is the (possible) absence of stick. HMRC announced today the introduction of their new Profits Diversion Compliance Facility (PDCF). This is a way for multinationals to take the initiative and explain their legal and operational structures before HMRC launch their next wave of full-scale “transfer pricing” investigations into corporates. The PDCF will be particularly relevant to groups with long established transfer pricing models which HMRC…

After much speculation, UK Chancellor Philip Hammond announced today in his annual budget speech that the UK will introduce a Digital Services Tax (DST) with effect from April 2020. In doing so, the UK has followed the example set with its Diverted Profits Tax by taking unilateral action first, and pre-empting possible EU and OECD proposals for a similar measure. This is despite stern criticism from the US Treasury and various quarters in business. The…

The Chancellor of the Exchequer’s statements of intent on a digital service tax and competition law reforms reinforce other recent indications that the UK government is looking seriously at making significant changes to the way it approaches online platforms and the so called “tech giants”. Brexit will potentially allow the UK to create its own strategy for the sector without necessarily needing to reach agreement with, or wait for, other European countries. Philip Hammond’s remarks…