---
title: "Research Specification into customers' experience of the Profit Diversion Compliance Facility & the Diverted Profits Investigation Approach"
ocid: "ocds-b5fd17-69bf2516-96f6-40a0-b1e4-360ddb0f3075"
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markdown_url: "https://d3tenders.com/contract/ocds-b5fd17-69bf2516-96f6-40a0-b1e4-360ddb0f3075.md"
json_url: "https://d3tenders.com/contract/ocds-b5fd17-69bf2516-96f6-40a0-b1e4-360ddb0f3075.json"
source: "Contracts Finder"
current_stage: "Award"
buyer: "H M REVENUE & CUSTOMS"
published: "2022-02-02"
---

# Research Specification into customers' experience of the Profit Diversion Compliance Facility & the Diverted Profits Investigation Approach

Buyer: H M REVENUE & CUSTOMS  
Current stage: Award  
OCID: ocds-b5fd17-69bf2516-96f6-40a0-b1e4-360ddb0f3075

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## Summary

HM Revenue & Customs (HMRC) is initiating a public procurement process titled "Research Specification into customers' experience of the Profit Diversion Compliance Facility & the Diverted Profits Investigation Approach". This tender falls under the research and development services category and is located in England. The procurement is at the Award stage, with the contract period commencing on 11th January 2022 and concluding on 29th June 2022. The minimum contract value is £43,992.88, while the total contract value is £50,000. Interested suppliers were required to submit their bids by 24th November 2021 through a selective procurement method, specifically via a call-off from a framework agreement.

This tender presents a significant opportunity for businesses engaged in research and consultancy services, particularly those with expertise in tax compliance and profit diversion analysis. Companies that can provide independent qualitative research and have prior experience with HMRC processes may find this contract particularly aligned with their capabilities. The findings from this research will be instrumental in shaping HMRC's strategies, ultimately leading to enhanced fiscal compliance which could benefit firms involved in similar areas of service delivery.

## Notice

Overview HM Revenue & Customs (HMRC) invites suppliers from the Research Marketplace agreement (RM6018) to undertake research aimed at understanding customers' experience of the Profit Diversion Compliance Facility (PDCF) and the Diverted Profits (DP) Investigation Approach. HMRC intends for this contract to be in place by 16th December 2021, with final outputs required by 29th June 2022. HMRC will maintain the overall management of the project. Context Profit diversion is HMRC's largest Corporation Tax risk, with the OECD estimating global tax losses of $100-240bn/pa. HMRC are keen to further improve efficient ways of tackling profit diversion. A key area of profit diversion is the diversion of profit (DP) by large groups that: (i) Seek to avoid creating a UK permanent establishment that would make a foreign company liable to pay UK Corporation Tax, or (ii) Use arrangements or entities that lack economic substance to exploit tax mismatches either through expenditure or the diversion of income within the group. There are two intervention approaches* to tackling profit diversion (all customers involved in this research will have completed one of these processes): 1.The PDCF: this facility gives multi-national enterprises (MNEs)using arrangements targeted by the Diverted Profits Tax (DPT) the opportunity to bring their UK tax affairs up to date. 2. DP enquiries: HMRC has identified a number of MNEs in a variety of business sectors that could be diverting profits. HMRC have established a Programme of investigation of the arrangements of these MNEs. This will involve a review of the customer's transfer pricing arrangements. Customers under enquiry may also face a potential DPT charge, which requires an upfront cash payment whilst the enquiry is ongoing if the relevant legislative conditions are met, and, depending on the cause of inaccuracies or failures to notify, they may face penalties or civil/criminal investigations. N.B. most PDCF and DP enquiries are settled by agreeing transfer pricing adjustments, in many cases, without DPT being charged. Independent qualitative research is essential to: *Understand independent customer views on the PDCF approach/process, informing design of new compliance facilities and accompanying guidance in significant tax risk areas. *Compare customer experience (PDCF-vs-enquiries). *Provide further insight to feed into the Large Business Tax Admin Review. *Understand the incentives and blockers for customers choosing to participate in the PDCF. The findings from this research will be used to inform improvements in HMRC's strategy for tackling profit diversion and consider the appropriateness of any wider use of a compliance facility for large business, delivering upstream/downstream yield, HMRC efficiencies and improved compliance standards.

## Key Details

| Field | Value |
| --- | --- |
| Publication source | Contracts Finder |
| Latest notice | https://www.contractsfinder.service.gov.uk/Notice/b987d0bf-be52-4276-a98d-1d611adf3d7e |
| Notice type | Award Notice |
| Procurement type | Framework |
| Procurement category | Services |
| Procurement method | Selective |
| Procurement method details | Call-off from a framework agreement |
| Tender suitability | Not specified |
| Awardee scale | Large |
| All stages | Award |

## Dates

| Field | Value |
| --- | --- |
| Publication date | 2 Feb 2022 |
| Submission deadline | 24 Nov 2021 |
| Future notice date | Not specified |
| Award date | 10 Jan 2022 |
| Contract period | 11 Jan 2022 - 29 Jun 2022 |
| Recurrence | Not specified |

## Values

| Field | Value |
| --- | --- |
| Tender value | £50,000 |
| Lots value | Not specified |
| Awards value | £50,000 |
| Contracts value | Not specified |

## Status

| Field | Value |
| --- | --- |
| Tender status | Complete |
| Lots status | Not specified |
| Awards status | Active |
| Contracts status | Not specified |

## Buyer

| Field | Value |
| --- | --- |
| Main buyer | H M REVENUE & CUSTOMS |
| Locality | SALFORD |
| Post town | Manchester |
| Postcode | M60 9LA |
| Country | England |
| ITL 1 | TLD North West (England) |
| ITL 2 | TLD3 Greater Manchester |
| ITL 3 | TLD34 Greater Manchester South West |
| Local authority | Salford |
| Electoral ward | Ordsall |
| Westminster constituency | Salford |
| Delivery location | TLC North East (England), TLD North West (England), TLF East Midlands (England), TLG West Midlands (England), TLH East (England), TLJ South East (England), TLK South West (England) |

## Supplier

| Field | Value |
| --- | --- |
| Number of suppliers | 1 |
| Supplier names | I.F.F RESEARCH |

## CPV Codes

### Divisions

- 73 - Research and development services and related consultancy services

### Codes

- 73000000 - Research and development services and related consultancy services

## Release History

- 2 Feb 2022 at 13:57 - Award - Award Notice - https://www.contractsfinder.service.gov.uk/Notice/b987d0bf-be52-4276-a98d-1d611adf3d7e

## Documents

- https://www.contractsfinder.service.gov.uk/Notice/b987d0bf-be52-4276-a98d-1d611adf3d7e
  2nd February 2022 - Awarded contract notice on Contracts Finder
- https://www.contractsfinder.service.gov.uk/Notice/Attachment/7d118be9-11a9-48ed-a3d0-cbdd57ccca8b
  Letter of Appointment
- https://www.contractsfinder.service.gov.uk/Notice/Attachment/27ee293e-9089-4304-8e73-f49e731ce2f8
  Call Off Contract

## Provenance

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