New disclosure facility for companies subject to DPT

HMRC has introduced a new ‘profit diversion compliance facility’ for multinational companies whose transfer pricing arrangements might bring them within the scope of diverted profits tax (DPT). The facility will allow companies to register before HMRC launches an investigation pay the tax and make a full report within six months which will be treated as an ‘unprompted’ disclosure for penalty purposes.

Companies are already required to notify HMRC within three months of the end of an accounting period in which they are potentially subject to DPT. In its accompanying guidance HMRC says that companies should not use the new facility if they are ‘confident that their transfer pricing is up to date and they are paying the right amount of...