INTM489705 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: consequences of section 86 applying - section 89 - calculation of profits where only tax avoidance condition is met

Section 89 applies where section 86 applies but the mismatch condition is not met. This means that the tax avoidance condition must be met.

Where section 89 applies, taxable diverted profits will be an amount equal to the notional PE profits.