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Home / Simons-Taxes /Business tax /Part B4 Transfer pricing and profit fragmentation /Division B4.1 Transfer pricing /Transfer pricing—interaction with other provisions / B4.192 Transfer pricing and diverted profits tax

B4.192 Transfer pricing and diverted profits tax

Business tax

The introduction of the diverted profits tax (DPT) arose because HMRC believed that some multinational enterprises were not correctly operating cross border pricing arrangements which met with the OECD transfer pricing guidelines¹. This could result in the diversion of UK profits to an overseas entity with lower tax rates and so the DPT was

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D6.503 International movement of capital—reportable transactions and events

I4.265 Lifetime transfers reported late

B5.301 Intellectual property—overview

B4.130 Summary of OECD guidelines on arm's length principle

I7.504 Designation for the conditional exemption

B2.306 General tests for distinguishing between capital and revenue expenditure

E5.406 Employees of European Union delegations—tax exemptions

E1.1502 Tax treatment of transfers with accrued interest

B2.315 The concept of wholly and exclusively

E4.1146 The PAYE cumulative basis—overview

B8.210 Restrictions on sideways loss relief

C3.305 Rollover relief—time limit for acquisition of replacement assets

C3.1705 Non-qualifying tax years, and disposals of a main home under NRCGT

E4.115 Employment income—place of performance of duties

I5.221 Lifetime termination of QIIP—general

C3.1713 PPR relief where a dependent relative occupied the residence prior to 6 April 1988

E7.234 Other types of lifetime benefit lump sum

C2.1016 Option to subscribe for shares in a company (share warrants)

B2.472 Tax and tax-related expenditure

D6.233 Rights issue—sale of rights nil paid