INTM489851 - Diverted Profits Tax: customer engagement with HMRC: what an initial informal discussion should cover

For the purposes of an initial discussion, customers should set out their understanding of the relevant facts and application of DPT to their circumstances. It is helpful if the customer provides copies of any supporting material they have which will aid understanding, such as presentations and internal explanatory papers and any financial analysis to support their own judgements with respect to any DPT analysis, where relevant (see also INTM489898). This information will be passed to the LB international Tax Specialist, or MSB Diverted Profits Technical Co-ordinator to consider. The CCM or MSB case team may ask questions to clarify factual matters and obtain further information but unless they are confident that the transactions discussed do not present a risk for DPT they must not give any opinions on the application of DPT without first consulting the LB international Tax Specialist, or MSB Diverted Profits Technical Co-ordinator.