Diverted profits tax: what happens next?

HMRC is currently setting up its diverted profits tax governance process, which includes the creation and recruitment of a specialist diverted profits team. This team will have transfer pricing support and, through CRMs, a link to the wider taxpayer relationship. While some of the scare stories surrounding the DPT are exaggerated, HMRC will now want to see a fuller global picture of taxpayers’ affairs to determine whether the pools of lowly taxed profits that arise outside the UK properly belong there. This is likely to impose a greater compliance burden on business, and perhaps also result in a greater transfer pricing yield.