INTM489894 - Diverted Profits Tax: notification, charging and payment: interaction with Corporation Tax penalties
In cases where the case is ultimately concluded by a corporation tax adjustment which replaces the DPT charge wholly or partially, it may be that the company is potentially liable to both a corporation tax inaccuracy penalty and a DPT failure to notify penalty based on the same profits. In such cases, please refer to CH76100 for guidance on the interaction.