UK Diverted Profits Tax Guidance Released

By Robert Robillard - 1 April 2015

This blogpost originally appeared on

On March 30, 2015, HM Revenue & Customs released the interim draft guidance on the diverted profits tax. It is available here.

A Summary of amendments following the technical consultation has also been published and is available here. The summary pertains to the following:

  • Narrowing the notification requirement;
  • Clarifying rules for giving credit for tax paid;
  • Clarifying the meaning of “excluded loan relationship”;
  • Simplifying the legislation by restructuring and clearer signposting;
  • Clarifying the economic substance test;
  • Clarifying the operation of the rule to address avoidance of a UK taxable presence (Permanent Establishment);
  • Exclusion of charities and other exempt bodies;
  • Application to land and property; and
  • Application to oil and gas ring fence regime.

Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P.
Senior Partner, RBRT Inc.
514-742-8086; robertrobillard “at”

The convergence of RBRT’s tax, accounting and economics expertise makes a difference. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from RBRT Inc. as required.