On 10 January 2019, UK HMRC published information on the new Profit Diversion Compliance Facility, which may be used to make disclosures of outstanding liabilities for profit diversion in relation to the Diverted Profit Tax (DPT). The new facility is designed to encourage MNEs to review both the design and implementation of their transfer pricing policies, change them if appropriate, and use the facility to put forward a report with proposals to pay any additional tax, interest and where appl…