The Financial Times reported yesterday on a survey sponsored by Pinsent Masons showing that the average HMRC investigation into a large company's tax affairs took 34 months in the year to March 2017 (an increase from the 31 months it took to March 2016).  The rise is put down to an increasingly aggressive approach by HMRC - which is under inevitable pressure to maximize revenue - and lack of resources at HMRC to enable it to conduct efficient investigations.

HMRC confirmed that at any one time it will be conducting an active investigation into more than half of the UK's largest 2,100 businesses.  If on average each of those investigations is lasting nearly three years, that represents an awful lot of management time at large companies and considerable uncertainty around their tax provisions. This stuff matters.  When coupled with the lack of an adequate ruling system which might allow businesses to obtain some certainty around the tax treatment of their transactions, it affects the attractiveness of the UK as a place to do business.