DST45000 - Allocating the DST Charge to Members of the Group

While DST is calculated based on the group’s total revenues, the liability to DST falls on the individual members of the group. Once the threshold conditions are satisfied, each member of the group is liable to DST.

The charge is then allocated to the individual members of the group that recognise the UK Digital Services revenues, in the proportion of their contribution to the group’s total UK Digital Services revenues.

This is the final stage of the calculation, under both the standard and alternative charge calculation. The legislation says:

• The DST liability of an individual member of the group in respect of the accounting period is the appropriate proportion of the group amount.

The appropriate proportion of the group amount is the UK DST revenue recognised by the member in proportion to the total UK DST revenue recognised by the group.

Example A

Group A consists of two companies. Company A receives all external revenue and Company B is an intragroup service provider. Both companies have near identical revenue recognised in their audited accounts. Both companies are relevant persons, given they were members of the group in the AP, and both are liable to DST.

However, as Company A is the only member of the group receiving UK Digital Services revenues, it will be liable for the entirety of the group amount.