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FA 2015: Diverted profits tax - a detailed guide to the rules

Sandy Bhogal (Mayer Brown) highlights key features and potential issues

First announced in parliament as part of the Autumn Statement on 3 December 2014 the diverted profits tax (DPT) legislation went through a single iteration on 10 December 2014 before being re-released with FB 2015 on 24 March 2015. It became law with the granting of royal assent to FA 2015 on 26 March. Although an open day for interested parties was held by HMRC on 8 January comments were invited only on the technical aspects of the legislation and the revisions at FA 2015 – though largely welcome – therefore did not dilute the controversial nature of the tax. ‘Interim draft guidance’ was released on 30 March 2015 revising the guidance that had been issued with the first draft of the...

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