Diverted Profits Tax (DPT) is part of the UK’s response to the shifting tax environment, most notably highlighted in the OECD’s BEPS reports. DPT is a new 25% tax introduced in April 2015 that goes beyond traditional Transfer Pricing to look at characterisation and commercial rationale underpinning intra-group arrangements.
DPT is a key priority for HMRC, with significant resources being invested by the tax authority with the aims of taxing profits that are considered diverted from the UK and ultimately changing the behaviours of businesses.
See the attached flyer for more information.