“The staggering truth established by the Eye – to which HMRC refuses to respond despite half a dozen requests – is that of the thousands of major corporation tax ruses set up since 2004, not a single one has been taken to a tribunal or court! All have been settled through “light touch” compromise agreements, often in breach of the department’s official policy and at immense cost to taxpayers.”
The real point that emerged is a simple one: not a single case of tackling transfer pricing was taken. Not a single case.
And in the Public Accounts Committee hearing we had this week we were told the following:
During a three-hour grilling of the multinationals, the Public Accounts Committee heard that Starbucks had secured a favourable “tax ruling” from the Dutch Government, which has requested confidentiality. The US-owned chain has been sending 6 per cent of British revenues to regional headquarters in Amsterdam in the form of royalties for intellectual property. After talks with Revenue & Customs, royalties were lowered to 4.7 per cent, but the change was described as “cosmetic” by the Conservative committee member Stephen Barclay.
This actually is transfer pricing being tackled. By negotiation, without the costs of courts or lawyers.
HMRC does have the power to tackle this without troubling the courts, does indeed use this power without troubling the courts and Ritchie then wants to complain about it?