Part 2 Recovery of Diverted Profits Tax from Related Companies

Part 2 Recovery of Diverted Profits Tax from Related Companies

Cases in which this Part applies

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(1)     This Part of this Schedule applies if—

(a)     an amount of diverted profits tax has been charged on a company for an accounting period,

(b)     the whole or any part of that amount is unpaid at the end of the due and payable date, and

(c)     the company is non-UK resident.

(2)     In this Part of this Schedule “the taxpayer company†means the company mentioned in sub-paragraph (1).

Meaning of “the relevant periodâ€

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In this Part of this Schedule “the relevant periodâ€, in relation to an amount of unpaid diverted profits tax for an accounting period of the taxpayer company, means the period—

(a)     beginning 12 months before the start of the accounting period, and

(b)     ending when the unpaid tax became payable.

Meaning of “related companyâ€

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(1)     A company is a “related companyâ€, for the purposes of this Part of this Schedule, if, at any time in the relevant period, it was a member—

(a)     of the same group as the taxpayer company,

(b)     of a consortium which at that time owned

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