The DPT charge is imposed by HMRC issuing a charging notice to the company1. Before issuing a charging notice, HMRC must issue a preliminary notice setting out the details of the proposed charge2.
Diverted profits tax—preliminary notice
Whether or not the company has made notification, where HMRC has reason to believe that the company is liable to the DPT they must issue a preliminary notice for the relevant period3.
Time limit for issuing a preliminary notice
A preliminary notice can only be issued4:
- Ìý
(a)ÌýÌýÌýÌý no more than six months after the last day on which an amendment to the company tax return for the relevant accounting period can be made (ignoring any exceptions to the standard period set out in FA 1998, Sch 18, para 15(4)5) for a DPT charge under FA 2015, s 80 (UK company: involvement of entities or transactions lacking economic substance) or FA 2015, s 81 (Non-UK company: involvement of entities or transactions lacking economic substance), or
- Ìý
(b)
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