Last chance to register

Philippe Freund considers the reasons for making a disclosure under the Profit Diversion Compliance Facility

On 10 January 2019, HMRC launched its Profit Diversion Compliance Facility (PDCF). This facility forms part of HMRC’s intensifying efforts to tackle perceived non-compliance by multinationals with legislation aimed to prevent them from shifting UK profits to low-tax jurisdictions. The registration deadline for the PDCF will expire on 31 December 2019 and companies are therefore now running out of time to review their policies and contractual arrangements and to determine whether or not they ought to register under the PDCF. The aim of this article is to provide an overview of the way in which the PDCF operates, as well as alternative ways of dealing with inconsistent practices and arrangements.