£4.1bn secured by HMRC through transfer pricing challenges

AN ADDITIONAL £4.1BN of revenue has been secured for the public purse through challenging transfer pricing arrangements since the creation of its Transfer Pricing Group in 2008, HM Revenue & Customs has claimed.

In a briefing published this week, the department said it was playing a “leading role” in a review of OECD rules on transfer pricing.

The method sees multinational corporations value and purchase goods and services moving across international borders from one of the group’s corporate entities to another.

An ‘arm’s length’ principle is typically applied, which sees internal transactions within the group charged at the market rate, although multinationals have recently been accused of using the process to shift profits to low-tax jurisdictions.

Despite public questions over HMRC’s record in curtailing profit-shifting and erosion of the tax base, the taxman has insisted in its briefing that its work represented good value.

“The group provides expert resource to identify and address transfer pricing risks. Since the group was formed, HMRC has secured £4.1 billion of additional tax for the UK Exchequer by challenging transfer pricing arrangements,” the briefing said.

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