DSG and HMRC in tax stalemate

HMRC and DSG International remain locked in discussions over a final settlement in a dispute over transfer pricing arrangements.

The case ­ which is being heard before the special commissioners ­ is thought to have been adjourned for the parties to reach agreement on the amount of tax involved in the decision. The commissioners effectively ruled in favour of HMRC in principle guidance they issued.

While sources have said an appeal by DSG, owners of electrical store Currys, is unlikely, a statement from the group said DSG ‘expects to appeal in the High Court’. The statement said: ‘Given the complex process to determine and agree such amounts, [the group] cannot at this stage confirm the timing or the amount that may fall due.’

The group said the decision will not have a material impact on its financial position. The case relates to intra-group trading arrangements between 1997 and 2005.