INTM489938 - Diverted Profits Tax: notification, charging and payment: appeals against charging notices and supplementary charging notices

A company may appeal against a charging notice or supplementary charging notice after the end of the review period. The appeal must be made to HMRC within 30 days of the end of the review period.

The appeal must be made in writing and must specify the grounds on which it is made.

Payment of DPT may not be postponed on any grounds, including any pending appeal.

For the purposes of an appeal, the special rules disallowing 30% of expenditure under the inflated expenses condition must be disregarded when determining whether the taxable diverted profits have been properly calculated.

Appeals may be settled by agreement between HMRC and the company or by the Tribunal.

In determining an appeal, the Tribunal has power to

• confirm the charging notice or supplementary charging notice
• amend the charging notice or supplementary charging notice
• cancel the charging notice or supplementary charging notice.