Commentary

D2.717 Liability to DPT

Corporate tax
Corporate tax | Commentary

D2.717 Liability to DPT

Corporate tax | Commentary

D2.717 Liability to DPT

Where foreign companies make substantial sales through activity in the UK while avoiding the creation of a UK permanent establishment there may be a potential liability to the DPT. Such arrangements are often combined with other arrangements that allow the foreign company to transfer profits associated with those sales to companies resident in territories where little or no tax is paid. It does not apply though where the exemptions detailed in D2.715 apply.

A company (FC) may be liable to diverted profits tax for that period if1:

  1.  

    (a)     it is non-UK resident in the accounting period

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