DPT administrative process

Produced by Tolley in association with

Corporation Tax

Guidance

There are several administrative matters and deadlines to be aware of in connection with diverted profits tax (DPT). The key provisions are listed below.

Duty to notify HMRC

A company is not required to self-assess its liability to DPT. Rather, if it is potentially within the charge to DPT, it is under a duty to notify HMRC within three months following the end of the relevant accounting period. For accounting periods ending on or before 31 March 2016 (ie the first year of application of DPT), the notification deadline was extended to six months from the end of the relevant period.

The notification must be made by the affected UK resident or foreign company in writing and must state:

•
whether the duty to notify arises as a result of FA 2015, ss 80 or 81 (entities or transactions lacking economic substance), or FA 2015, s 86 (avoidance of a UK permanent establishment

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Paul Bowes

International Tax Consultant at Paul R Bowes

Paul Bowes is an independent tax consultant who principally advises on corporate structuring and the taxation of foreign profits, having previously worked in practice with leading accounting firms and within the banking sector. He has actively participated in the various consultations relating to the reform of company taxation that have taken place in the UK in the last decade or so, including the reform of the controlled foreign companies' rules.

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