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In this article, we summarise the main updates to the Diverted Profits Tax guidance that was published on 31 December 2018. These updates may affect companies that are already discussing their arrangements with HMRC or who could potentially be within the scope of DPT. This remains an area of HMRC focus as demonstrated by the launch of the Profit Diversion Compliance Facility on 10 January.

HMRC's updated guidance on DPT can be found here.

In summary the main amendments are:


A summary of the all the changes to the guidance can be found here and comparison with the last guidance highlighting the changes can be seen here.