INTM489954 - Diverted Profits Tax: notification, charging and payment: collection of tax from a non-UK resident
The rules in Chapter 6 of Part 22 CTA 2010 apply to the assessment, collection and recovery of DPT, or interest on DPT from a non-UK resident company. These rules mean that tax and interest can be collected from a permanent establishment (PE) in the UK through which a non-UK resident carries on a trade. They also apply to an avoided PE for the purposes of the DPT. The permanent establishment or the avoided PE is treated as the UK representative of the non-UK company in relation to the taxable diverted profits arising to the non-UK company.