UK Law and Practice Contributed by: Russell Warren and Michael Langan, King & Spalding LLP
Profit Diversion Compliance Facility HMRC launched the Profit Diversion Compliance Facility in 2019. This is a voluntary scheme intro - duced by HMRC to encourage businesses to volun - tarily review and adjust their transfer pricing position. It is mainly designed to encourage engagement with HMRC where there are concerns around profit diver - sion, particularly to lower-tax jurisdictions.
the tax payor to ensure it remains in compliance with its tax obligations. Advance Thin-Cap Pricing Agreements Similar to APAs, advance thin-cap pricing agreements provide certainty in the context of intercompany financings in areas such as debt levels, interest rates and availability of interest deductions. Unlike APAs, however, these agreements are always unilateral and agreed only with HMRC. Non-Statutory Clearance Applications Taxpayers may also make applications to HMRC for non-statutory clearances in respect of certain transac - tions. Such applications are typically made in areas where tax law is unclear and they require full dis - closure of the transaction and surrounding facts to HMRC. Applications can be made both by individual tax payors and by businesses.
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