Giant multinationals are responsible for nearly half of the £25bn in tax revenue that HMRC suspects is not being paid by big businesses in the UK, quashing the myth that a light touch to foreign investment exists within the department, say Pinsent Masons.

Jason Collins, head of tax, at Pinsent Masons said: 'HMRC actively targets foreign-owned companies within the UK, as they do UK-owned companies, to see if they owe any extra tax.

'There is the perception that HMRC and the Treasury are so eager to attract foreign companies to the UK that they are happy to take any tax payment that they get. That just isn't the case.'

Foreign-owned companies account for 44% of the tax that HMRC has earmarked as potentially being underpaid by big business, with £11bn believed to be kept from the revenue's reach, but Collins wonders whether that figure is exaggerated.

'Only a fraction of that £11bn is actually owed to HMRC. Aggressive tax avoidance among large companies just isn't as widespread as some would have us believe. HMRC itself recognises that the £11bn is just the total tax under consideration; only around half of the estimate of tax under consideration is eventually brought into charge,' he added.

Following on from the furore over Starbucks reduced tax bill, the legal firm reject calls for changes to the transfer pricing rules in place. Collins said: 'All the evidence is that HMRC is very proactive in challenging transfer pricing arrangements that it does not like. Besides, in HMRC's overall list of priorities for missing tax, transfer pricing is quite low down.

'No one has pointed to any hard evidence that Starbucks UK's payment of a royalty fee to the Starbucks European headquarters for using the Starbucks brand is out of the ordinary.'