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Committee stage, except clauses 1 to 8, schedules 1 and 2, clauses 9, 10, 69 and 62, schedule 12, clauses 63 to 68 and 83 to 85, schedule 13, clause 86 and any new clauses or new schedules relating to the subject matter of these clauses and schedules. Clause 35, discussed with new clauses 28 and 29, agreed to. Clause 36, discussed with clauses 37 and 38 stand part, all agreed to. Clauses 40 and 41 agreed to. Clause 43, discussed with amendments, Schedule 3, and clause 44 stand part. Clauses 43 and 44 agreed to. Two amendments to schedule 3 negatived on division (3 votes to 10 respectively). Clause 45 agreed to. Schedule 4 agreed to. Clause 46, discussed with schedule 5, agreed to. Schedule 5 agreed to. Clause 47, discussed with a Government amendment and schedule 6, agreed to. Schedule 6 agreed to as amended. Clause 48, discussed with new clause 4, agreed to. Clause 49 agreed to. Schedule 7 agreed to. Clause 50, discussed with Government amendments, schedule 8, and new clause 5, agreed to. Schedule 8 agreed to as amended. Clause 51 agreed to. Clause 52, discussed with new clause 6, agreed to. Clause 53, discussed with new clause 7, agreed to. Clause 54, discussed with schedule 9 and new clauses 8 and 9, agreed to. Schedule 9 agreed to. Committee adjourned till 29 January. Written evidence reported to the House.
Committee stage, except clauses 1 to 8, schedules 1 and 2, clauses 9, 10, 69 and 62, schedule 12, clauses 63 to 68 and 83 to 85, schedule 13, clause 86 and any new clauses or new schedules relating to the subject matter of these clauses and schedules. Clause 35,...
(Except clauses 5 and 6, 7 to 9, 10 to 15, schedule 1, clauses 18 to 25, 27, 47, 48, 50 to 60, schedules 7 to 9, clauses 121 to 264, schedules 14 to 17, clauses 265 to 277, schedule 18, clauses 278 to 312 and any new clauses or new schedules relating to the subject matter of those clauses and schedules.) Clauses 36 to 38 agreed to. Schedule 5 agreed to. Clauses 39 and 40 agreed to. Clauses 41 and 42 agreed to as amended. Clauses 43 to 46 and 49 agreed to. Schedule 6 agreed to. Clauses 61 to 71 agreed to.
(Except clauses 5 and 6, 7 to 9, 10 to 15, schedule 1, clauses 18 to 25, 27, 47, 48, 50 to 60, schedules 7 to 9, clauses 121 to 264, schedules 14 to 17, clauses 265 to 277, schedule 18, clauses 278 to 312 and any new clauses or...
To ask the Chancellor of the Exchequer, what penalties apply to multinational companies that fail to submit required transfer pricing information within the deadline set by HMRC.
To ask the Chancellor of the Exchequer, what penalties apply to multinational companies that fail to submit required transfer pricing information within the deadline set by HMRC.
The filing of transfer pricing documentation alongside the tax return is not currently compulsory in the UK.
Taxpayers should prepare and retain such transfer pricing documentation as is reasonable given the nature, size and complexity of their business or of the relevant transaction but which adequately demonstrates that their transfer pricing meets the arm’s length standard. HMRC’s aim is to address this issue effectively while ensuring that businesses do not suffer disproportionate compliance costs.
In the event of a compliance check by HMRC, if the business has not provided all the documents and information requested, HMRC have the power to issue a notice to the business requiring it to provide information and documents that HMRC reasonably require for the purpose of checking its tax position.
If the business does not provide the information or produce the documents requested, HMRC may charge a penalty unless there is a reasonable excuse for the failure.
If the failure continues, HMRC may charge daily penalties. If HMRC consider that the maximum daily penalties that can be assessed are insufficient for the particular case or the that records have been destroyed, a tax-related penalty may be appropriate.
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of transactions under investigation; and how many inquiries resulted in the view that the factual pattern outlined to HMRC at the start of an enquiry...
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of transactions under investigation; and how many inquiries resulted in the view that the factual pattern outlined to HMRC at the start of an enquiry...
On 10 January 2019 HMRC introduced a new Profit Diversion Compliance Facility for Multi-National Enterprises using arrangements targeted by the Diverted Profits Tax (DPT) to give them the opportunity to bring their UK tax affairs up to date.
HMRC does not hold the information about the value of transactions under investigation.
HMRC does not hold information about how many inquiries resulted in the view that the factual pattern outlined to HMRC at the start of an enquiry did not stand up to scrutiny once tested in each of the last five years.
However, in circumstances where HMRC believes it may have been misled by information provided by customers in the context of transfer pricing investigations, the matter will be referred to its Fraud Investigation Service.
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of transactions through transfer pricing arrangements in each of the last five years; how many transfer pricing specialists HMRC employs; and how many transfer pricing...
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of transactions through transfer pricing arrangements in each of the last five years; how many transfer pricing specialists HMRC employs; and how many transfer pricing...
On 10 January 2019 HMRC introduced a new Profit Diversion Compliance Facility for Multi-National Enterprises using arrangements targeted by the Diverted Profits Tax (DPT) to give them the opportunity to bring their UK tax affairs up to date.
HMRC does not hold the information about the value of transactions through transfer pricing arrangements in each of the last five years.
HMRC has increased the number of staff dealing with international tax risks, including transfer pricing. As at 30 April 2018, there were 365 full time equivalent staff working on international risks, including transfer pricing and DPT. HMRC recognises the importance of identifying and tackling international tax risks and is invested in building the capability of the staff involved. These skilled staff work with other expert industry and tax specialists to tackle those cases that represent a substantial risk of tax loss to the Exchequer in line with HMRC’s “resource to risk” compliance policy.
Transfer pricing investigations include enquiries into tax returns, pre-return investigations, and investigations that precede Advance Pricing Agreements (APAs) or Advance Thin Capitalisation Agreements (ATCAs). The numbers of transfer pricing investigations HMRC initiated in the years 2013/14 to 2017/18 were:
| 2013/14 | 2014/15 | 2015/16 | 2016/17 | 2017/18 |
Number of Investigations | 462 | 427 | 384 | 250 | 244 |
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of the sums recovered from HMRC investigations into transfer pricing arrangements in each of the last five years; how many HMRC investigations into transfer pricing...
To ask the Chancellor of the Exchequer, with reference to HMRC's January 2019 Profit Diversion Compliance Facility, what estimate he has made of the value of the sums recovered from HMRC investigations into transfer pricing arrangements in each of the last five years; how many HMRC investigations into transfer pricing...
On 10 January 2019 HMRC introduced a new Profit Diversion Compliance Facility for Multi-National Enterprises using arrangements targeted by the Diverted Profits Tax (DPT) to give them the opportunity to bring their UK tax affairs up to date.
In the years from 2012/13 to 2017/18, HMRC secured £6.5 billion of additional tax by challenging the transfer pricing arrangements of multinationals.
Year | 2012/ 13 | 2013/14 | 2014/15 | 2015/16 | 2016/17 | 2017/18 |
Total Amount | £504 m | £1,137m | £707m | £853m | £1,618m | £1,682m |
The information requested regarding how many HMRC investigations into transfer pricing arrangements have been subsequently referred to its Fraud Investigation Service in each of the last five years is not readily available and could only be provided at disproportionate cost. However, in appropriate cases transfer pricing cases are referred to HMRC’s Fraud Investigation Service for their consideration.
HMRC cannot reliably predict the value of its current investigations into transfer pricing arrangements because the outcome is highly dependent on the facts that are determined during the enquiries’ progress.
To ask Mr Chancellor of the Exchequer, what steps the Government is taking to prevent multinational companies using the transfer pricing method to avoid paying taxes.
To ask Mr Chancellor of the Exchequer, what steps the Government is taking to prevent multinational companies using the transfer pricing method to avoid paying taxes.
The transfer pricing rules set out how transactions between connected parties are priced for tax purposes. In common with most countries the UK rules are based on the internationally recognized armâs length principle. HM Revenue & Customs (HMRC) challenges arrangements that do not allocate the right amount of profits to the UK.
The Government has led the way in taking action to ensure multinational companies pay their fair share of taxes. We played a critical role in establishing the OECD project to strengthen international tax standards to help counter base erosion and profit shifting.
The Government has gone further by taking a lead in the implementation of measures to address that profit shifting, for example, introducing the Diverted Profits Tax (DPT). This measure encourages businesses that are using contrived arrangements to minimise their tax liabilities, to change those behaviours or face paying tax at a higher rate.
HMRC deploys specialist staff to deal with international tax risks, including transfer pricing and diversion of profits. These experts work with other industry experts and tax specialists to tackle all international tax issues that represent substantial risk of tax loss to the Exchequer. HMRC also works with other tax authorities, sharing information and expertise, to identify risk and challenge arrangements. The recent introduction of Country by Country reporting will also increase the information available to HMRC and assist their risk assessment processes to identify these tax risks.
To ask Her Majesty’s Government whether they have discontinued the publication of annual Transfer Pricing statistics; and if so, why.
To ask Her Majesty’s Government whether they have discontinued the publication of annual Transfer Pricing statistics; and if so, why.
HM Revenue and Customs has not discontinued the publication of these statistics. The Department intends to publish the transfer pricing statistics shortly.
To ask Mr Chancellor of the Exchequer, whether his Department has discontinued the publication of annual transfer pricing statistics.
To ask Mr Chancellor of the Exchequer, whether his Department has discontinued the publication of annual transfer pricing statistics.
HM Revenue and Customs has not discontinued the publication of these statistics. The Department intends to publish the transfer pricing statistics shortly.
The Bill introduces measures on small business investment that will simplify the tax system and ensure that allowances are fair and not open to abuse.
Clause 41 charges corporation tax for the financial year beginning 1 April 2017. Corporation tax is an annual tax approved by Parliament each year. This is...
The Bill introduces measures on small business investment that will simplify the tax system and ensure that allowances are fair and not open to abuse.
Clause 41 charges corporation tax for the financial year beginning 1 April 2017. Corporation tax is an annual tax approved by Parliament each year. This is...
To ask Mr Chancellor of the Exchequer, how many transfer pricing cases have been opened with HM Revenue and Customs' transfer pricing unit in each year since 2008-09; how many such cases have been closed in each such year; and how much was raised in each such year.
To ask Mr Chancellor of the Exchequer, how many transfer pricing cases have been opened with HM Revenue and Customs' transfer pricing unit in each year since 2008-09; how many such cases have been closed in each such year; and how much was raised in each such year.
HM Revenue and Customs (HMRC) publishes annual statistics reporting its performance across its transfer pricing work, including enquiries, advance pricing agreements, advance thin capitalisation agreements and mutual agreement procedure cases. The most recent published statistics are for 2013- 14. HMRC intends to publish the statistics for 2014-15 shortly. These statistics answer many of the individual questions asked. However, HMRC does not hold information centrally in a form which allows it to answer all the questions asked in the required timeframe.
The aim of the Advance Pricing Arrangements (APA) Programme is to provide businesses with certainty on the pricing of complex intra-group transactions. An APA sets out the method for determining, in accordance with the law, the transfer price for intra-group transactions. APAs are part of the internationally recognised best practices recommended by the OECD. HMRC has published guidance about what APAs are, the circumstances where it would be appropriate for businesses to apply for an APA and what information is required before any agreement can be made.
(Except clauses 16, 17, 43 and 45 and schedules 2 and 3). Clauses 37 to 39 agreed to. Clause 40, discussed with new clause 2 (Tax treatment of private equity fund managers' pay), agreed to. New clause 2 not moved. Clause 41 agreed to. Clause 42, discussed with new clause 5 (VED rate: impact on carbon dioxide emissions) agreed to on division (14 votes to 10). Clauses 44 and 46 agreed to.
(Except clauses 16, 17, 43 and 45 and schedules 2 and 3). Clauses 37 to 39 agreed to. Clause 40, discussed with new clause 2 (Tax treatment of private equity fund managers' pay), agreed to. New clause 2 not moved. Clause 41 agreed to. Clause 42, discussed with new clause...
To ask Mr Chancellor of the Exchequer, what recent discussions he has had with his foreign counterparts about reforms to transfer pricing arrangements.
To ask Mr Chancellor of the Exchequer, what recent discussions he has had with his foreign counterparts about reforms to transfer pricing arrangements.
i. Letter dated 22/07/2013 from George Osborne MP to Andrew Tyrie MP regarding the OEC action plan on base erosion and profit shifting. 2 p. II. Action plan on base erosion and profit shifting. 44 p.
i. Letter dated 22/07/2013 from George Osborne MP to Andrew Tyrie MP regarding the OEC action plan on base erosion and profit shifting. 2 p. II. Action plan on base erosion and profit shifting. 44 p.