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DSG and HMRC in tax stalemate


HMRC and DSG International remain locked in discussions over a final
settlement in a dispute over transfer pricing arrangements.

The case ­ which is being heard before the special commissioners ­ is thought
to have been adjourned for the parties to reach agreement on the amount of tax
involved in the decision. The commissioners effectively ruled in favour of HMRC
in principle guidance they issued.

While sources have said an appeal by
owners of electrical store Currys, is unlikely, a statement from the group said
DSG ‘expects to appeal in the High Court’. The statement said: ‘Given the
complex process to determine and agree such amounts, [the group] cannot at this
stage confirm the timing or the amount that may fall due.’

The group said the decision will not have a material impact on its financial
position. The case relates to intra-group trading arrangements between 1997 and

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