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But if they had done this by recharging costs from low tax jurisdictions to the UK, then unless these charges were at an arms length rate, ie what a company would pay a 3rd party for providing those services, then they would fall foul of the transfer pricing rules. I haven't seen anything...

I agree that if they have been loss making for 14 years and are paying large intra-group management charges, interest etc then one would suspect that their transfer pricing may not be correct. But if this was the case, why would HMRC not have queried this. As I said in my earlier post, I don't...

The thing to consider here is that uk tax policy is to reduce the corporation tax burden (30% rate in 2007 down to 22% in 2013) and also offer incentives to multi-nationals such as the patent box regime (qualifying profits taxed at 10%) and the finance co CFC rules (effective tax rate 5.75%)...