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 investigations HMRC has undertaken in each of the last five years.
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:
Number of Investigations