HMRC is increasingly targeting multinationals, in particular by questioning their transfer pricing arrangements and ensuring that they are not artificially diverting profits away from the UK. Additionally, HMRC has made a number of arrests and begun criminal investigations in relation to suspected fraud concerning the coronavirus job retention scheme. In Blackrock, HMRC’s transfer pricing and ‘unallowable purpose’ challenges failed, although the decision is expected to be appealed. Meanwhile, taxpayers continue to face significant obstacles when seeking to exercise their public law rights in challenging a decision of HMRC, as recently demonstrated in RT Rate Ltd.
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HMRC is increasingly targeting multinationals, in particular by questioning their transfer pricing arrangements and ensuring that they are not artificially diverting profits away from the UK. Additionally, HMRC has made a number of arrests and begun criminal investigations in relation to suspected fraud concerning the coronavirus job retention scheme. In Blackrock, HMRC’s transfer pricing and ‘unallowable purpose’ challenges failed, although the decision is expected to be appealed. Meanwhile, taxpayers continue to face significant obstacles when seeking to exercise their public law rights in challenging a decision of HMRC, as recently demonstrated in RT Rate Ltd.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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