This paragraph describes how taxable diverted profits arising in connection with a non-UK company avoiding a UK taxable presence (by virtue of FA 2015, s. 86) are calculated for an accounting period. It also considers the additional rules which apply where the taxable diverted profits are to be estimated for the purposes of issuing a preliminary notice (¶777-580) or a charging notice (¶777-640) (FA 2015, s. 88(1) and (2)).

Amount of taxable diverted profits

The taxable diverted profits arising to the foreign company in an accounting period in connection with a non-UK company avoiding a UK taxable presence (where FA 2015, s. 86 applies) are: