The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).
Extensive reform to the UK’s diverted profits tax (DPT) is one of three topics covered by HMRC’s recent consultation Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax which closed for responses on 14 August 2023. DPT in force since 2015 has been one of HMRC’s most effective tools in countering contrived arrangements designed to avoid profits being taxed in the UK and in re-establishing the balance of power in transfer pricing enquiries in favour of HMRC. The proposed reforms which include bringing DPT into corporation tax would if implemented without doubt take some of the venom out of DPT’s ‘sting’ reflect fairly significant concessions from HMRC and are...
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The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).
Extensive reform to the UK’s diverted profits tax (DPT) is one of three topics covered by HMRC’s recent consultation Reform of UK law in relation to transfer pricing permanent establishment and diverted profits tax which closed for responses on 14 August 2023. DPT in force since 2015 has been one of HMRC’s most effective tools in countering contrived arrangements designed to avoid profits being taxed in the UK and in re-establishing the balance of power in transfer pricing enquiries in favour of HMRC. The proposed reforms which include bringing DPT into corporation tax would if implemented without doubt take some of the venom out of DPT’s ‘sting’ reflect fairly significant concessions from HMRC and are...
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