When it Comes to Transfer Pricing Compliance, HMRC Says Get the Functional Analysis Right

When it Comes to Transfer Pricing Compliance, HMRC Says Get the Functional Analysis Right

The transfer pricing of multinational companies has always been a priority for HMRC. The British tax authority was among the first to develop a diverted profits tax and it’s constantly suspicious that multinational companies are parking tax dollars outside the jurisdiction via base erosion and profit shifting—in 2022, the latest statistic, HMRC claimed that U.S. multinationals underpaid the UK in tax by 5.6 billion pounds.   Suffice it to say, H…