The matter, which first came to light in February last year, and is being investigated under the Hansard procedure, led PwC to qualify the company’s 2003 results. Hansard allows companies to settle tax disputes without fear of prosecution.
‘We believe that there is significant uncertainty in respect of the amount of tax relief, which will eventually be agreed,’ the PwC audit qualification statement said. It went on to say that the tax, interest and penalties ‘may exceed the amount in creditors by up to £20m’. In the accounts, TNT states its liabilities amount to £19.9m.
PwC said that its opinion arises from ‘disagreement about the quantum of tax related liabilities’.
The amount of tax due to the Revenue from TNT, a subsidiary of Dutch group TPG, related to the ‘tax treatment of licence fees payable to another company in the TPG group’.
A TPG spokesman confirmed the disagreement with PwC, but urged that ‘it did not stop PwC signing off the group’s accounts’.
The company’s directors were advised in 2004 that a previously released settlement deal may be reopened.
A Revenue spokeswoman said that it was unable to comment on an individual company.
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