Non-UK company avoiding UK taxable presence
Calculation of taxable diverted profits
Amount
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
Exceptions
Definitions for purposes of section 87, limited UK-related sales or expenses
Definitions for purposes of sections 88–91
Exception
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
Definitions
Exemptions under FA 2015, s. 107(6)