HMRC intends to disallow interest deductions – available for taxpayers paying certain types of interest – claimed by General Electric (GE) Capital, the financial services division of the American conglomerate between 2004 and 2015.
“GE complies with all applicable tax laws and judicial doctrines of the UK, where we have operated for more than 100 years and where we employ around 16,000 people,” a GE spokesperson said.
“We believe that there are no other jurisdictions in which the outcome of unresolved issues or claims is likely to be material to our results of operations, financial position or cash flows,” the company stated in a regulatory filing.
“We further believe that we have made adequate provision for all income tax uncertainties.”
An HMRC spokesperson said the Revenue does not comment on identifiable taxpayers.
“We make sure that large businesses, just like everyone else, pay all the taxes due under UK law and we don’t settle for less,” they added.
In last week’s Budget, chancellor Philip Hammond announced his intention to tax large digital companies that make profits in the UK.
His decision drew criticism due it part to the complication of determining what businesses the tax might affect, and the impact it would have on business due to its complexity.
US Chamber of Commerce CEO Tom Donohue suggested that singling out specific sectors “set a dangerous precedent”.
Reports in October found that HMRC estimated that the potential tax take from UK telecommunications and information businesses could be as much as £2.5bn, with commentators suggesting that HMRC is setting its sights on the tech sector.