HMRC have announced that it will be holding a webinar on Tuesday 6 October to provide an update on its Profit Diversion Compliance Facility (PDCF). The facility is a mechanism that multinational firms can use to settle potential tax liabilities for past years that remain open. It relates to transfer pricing, the diverted profits tax, and other relevant areas of UK tax. This could include permanent establishment, WHT, CFCs, hybrid mismatch rules, and corporate residence.
This webinar follows HMRC sending out its fourth batch of nudge (warning) letters a fortnight ago, and marks a return to business as usual. If you have received one of these letters, action is imperative. As a minimum that includes reviewing your potential exposure. For some groups, using the facility may make sense. For others it won’t, but groups falling into this category should consider writing to HMRC to explain why they have no need to register. For groups with a UK presence that have not received a letter, conducting a review may still be sensible.
Our experience is that clear sailing in the past does not necessarily mean safe passage now. That’s even where there has been an APA or an audit settlement. Our team would be pleased to use experience gained from years spent on both sides of the table to help, starting with a high-level independent review, and talking you through the process.
Take a look at our PDCF brochure to find out more.
Authored by Graham Poole