Multinationals are talking to Revenue & Customs about extricating themselves from tax planning structures that backfired in the recession, amid qualms the UK could lose out if other governments were to take a tougher line.

The downturn is expected to heighten cross-border tax disputes about intra-company transactions, which can involve billions of pounds of tax revenues, as cash-strapped governments compete for what they see as a “fair share” of revenues. Most multinationals view their “transfer pricing” arrangements, which determine where taxable profits are earned, as their most troublesome tax issue.