Calculation of taxable diverted profits


Estimating profits for preliminary and charging notices in section 86 cases

Foreign company, meaning

Inflated expenses condition

Mismatch condition met, actual provision not met

Relevant expenses, meaning

Circumstances where DPT charge arises under section 86


Definitions for purposes of section 87, limited UK-related sales or expenses

Definitions for purposes of sections 88–91


Activity of avoided PE is an agent of independent status

Companies with limited UK sales or expenses

Small and medium-sized companies

Mismatch condition

Participation condition

Directly participating, meaning

Indirect participation, meaning

Tax avoidance condition

Tax mismatch outcome


Exemptions under FA 2015, s. 107(6)