INTM489848 - Diverted Profits Tax: customer engagement with HMRC: no formal statutory or non-statutory clearance procedure for Diverted Profits Tax

There is no formal statutory, or non-statutory clearance procedure for DPT.

HMRC is committed to meeting its international exchange of information obligations. If HMRC provides an opinion on the application of DPT to customer arrangements this may constitute a “ruling” for international taxation purposes, meaning it is very likely to be required to be exchanged with another jurisdiction.

For more information, including whether, when, and how HMRC exchange or make a request from foreign fiscal authorities for such rulings: please consult IEIM500000 onwards.

Additionally, HMRC will not usually provide an informal view on whether transactions are likely to fall within the scope of DPT, as it would require a considerable amount of resource from the company and HMRC to obtain the necessary assurance about the level of DPT risk.

Any opinion will not be influenced by the customer’s overall Business Risk Rating.