THE IRISH LOOP


l Transfer pricing and value creation need to be properly documented, not sketched on the back of a menu.


For private hire, this might mean actually having people in Ireland performing tech, admin, or management services if that’s what the paperwork says. A “brass plate” company that does nothing but issue an annual invoice to your UK firm is asking for trouble.


2. “Everyone else is doing it” is no defence


Because the Irish Loop is now a recognised pattern, HMRC can compare cases:


l If one operator has a robust, well evidenced arrangement and another has a paper thin copy, the second is exposed.


l The existence of compliant examples does not protect weaker ones; in fact, it can highlight where yours falls short.


For private hire bosses, this means:


l Don’t assume that because a competitor boasts about an Irish structure, it is either safe or suitable for you.


l Don’t rely on generic marketing material from scheme promoters. Insist on tailored, written advice from a regulated professional who understands your specific business.


Remember: HMRC’s job is to collect the right tax, not to level the playing field between operators. If your version of the Irish Loop doesn’t stack up, pointing at someone else’s won’t help.


3. HMRC may accept the structure but still challenge the numbers


Another key implication is that tax authorities can:


l Accept the broad shape of an Irish Loop structure, yet


l Still dispute how much profit is shifted, which company should bear particular costs, or how prices are set between UK and Irish entities.


For private hire operators this could show up as:


l Disputes over the level of platform or management fees charged by the Irish company


PHTM JULY 2026


l Arguments about whether key decisions are really taken in the UK rather than Ireland


l Questions around whether driver or customer facing functions (which create much of the value) are properly rewarded in the UK


In other words, even where the model is not torn up, the tax saving may be reduced or removed by an adjustment, potentially years after the fact and with interest and penalties on top.


Practical steps for operators considering (or already using) an Irish structure


If any of this rings bells, there are some sensible actions to take:


1. Get independent advice


Speak to a UK tax adviser or solicitor who is not the original promoter of the structure. Ask them to review the arrangement in plain English: what it does, why it works, and where the risks are.


2. Check that reality matches the story


Look at who is really doing what, where. If the Irish company is meant to be running technology, customer service, or management functions, make sure that is actually happening and evidenced.


3. Keep thorough records


Minutes, service agreements, transfer pricing reports, and correspondence should all support the idea that the Irish company is a genuine, profit earning part of the group.


4. Plan for HMRC questions


Assume at some point you may have to explain the structure. Being ready with a clear narrative and supporting paperwork is far better than trying to reconstruct it under pressure.


The bottom line for UK private hire operators is this: the Irish Loop is no longer an obscure idea muttered about at conferences; it is a recognisable pattern that HMRC now has language for and experience with. That doesn’t make it automatically wrong, but it does mean that only well designed, properly implemented versions are likely to stand up to scrutiny.


For everyone else, the promise of quick tax savings may come with a long and expensive tail.


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