According to HMRC, the launch of this new disclosure facility represents a ‘last chance saloon’ for companies to close cross-border arrangements and pay what they owe. Essentially the new disclosure facility is available to multinational companies that believe they may come within the Diverted Profits Tax regime but have not yet notified HMRC or met their obligations under the legislation.

The profit diversion compliance facility enables multinationals to bring their tax affairs up to date “openly and efficiently, giving them certainty for the past and a low risk outcome for profit diversion in the future”. HMRC aims to respond to proposals within 3 months of submission, provided a full and accurate disclosure is made.