D2.717 Avoiding a UK taxable presence—liability to diverted profits tax
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. However, no charge to DPT arises where the exemptions detailed in D2.718 apply.
A company (FC) may be liable to diverted profits tax for that period if1:
- Ìý
(a)ÌýÌýÌýÌý it is non-UK resident in the accounting period
- Ìý
(b)ÌýÌýÌýÌý it carries on a trade during all or part of the period
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Web page updated on 17 Mar 2025 14:53