INTM489730 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: the participation condition A - financing arrangements

The condition is met if at the time of making or imposing the material provision or within a period of six months beginning with the date the material position is made or imposed

• one of the relevant parties was directly or indirectly participating in the management, control or capital of the other, or
• the same person or persons was or were directly or indirectly participating in the management, control or capital of each of the relevant persons.