A high level brochure setting out an overview of the DPT rules, when they may apply and frequently asked questions.
DPT applies differently to non-UK companies in comparison to UK companies.
For a non-UK tax resident company, DPT broadly applies where arrangements have been put in place to avoid a UK taxable presence being created. For a UK tax resident company, DPT generally applies where profits are regarded as diverted to foreign companies that are not subject to an effective tax rate of at least 80% of the UK tax rate.
This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.