Budget 2015: Diverted Profits Tax – the elephant remains, albeit a bit smaller

Budget 2015: Diverted Profits Tax

Budget 2015: Chris Morgan, Head of Tax Policy at KPMG, has a mixed reaction on the announcement regarding Diverted Profits Tax.

Also on KPMG.com

Commenting on announcements in today’s Budget on the Diverted Profits Tax, Chris Morgan, Head of Tax Policy at KPMG in the UK, said:

“It’s good to see the Chancellor has listened to representations, in particular narrowing the notification requirement.

“While the devil will certainly be in the detail, this should reduce the admin burden on companies and ensure HMRC is not inundated with a wave of protective notifications.

“The Red Book also refers to new specific exclusions which helps to narrow the scope. However, it does not address the definition of substance, so the rule is still likely to create uncertainty for companies and leave too much discretion to HMRC in the way it is applied.

“Like an elephant, you know artificial diversion when you see it but it’s difficult to define in law. With today’s announcements, the Chancellor has narrowed the scope, but the fact remains that it’s still an elephant.”



For media enquiries, please contact:

Jessica Liebmann, KPMG Corporate Communications

M: +44 (0)7551 135 778

E: jessica.liebmann@kpmg.co.uk

KPMG Press office: +44 (0) 207 694 8773


Follow us on twitter: @kpmguk #budget15

Chancellor’s Budget 2015


About KPMG

KPMG LLP, a UK limited liability partnership, operates from 22 offices across the UK with approximately 12,000 partners and staff.  The UK firm recorded a turnover of £1.9 billion in the year ended September 2014. KPMG is a global network of professional firms providing Audit, Tax, and Advisory services. It operates in 155 countries and has 162,000 professionals working in member firms around the world. The independent member firms of the KPMG network are affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.  Each KPMG firm is a legally distinct and separate entity and describes itself as such.

This article represents the views of the author only, and does not necessarily represent the views or professional advice of KPMG in the UK.

Connect with us


Request for proposal



KPMG’s new-look website

KPMG’s new-look website