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ARTICLE · 12 AUGUST 2015

UK Diverted Profits Tax Update

Fieldfisher
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In what follows I have not gone into huge detail on DPT. That is for the experts, including my colleagues in our tax team, other tax advisers and the accountants.

United KingdomTax

Summary of events since my last blog:

  • DPT has come into effect (1 April 2015) .
  • DPT is a 25%  tax surcharge, and is here to stay.  By an amendment, prior to the Finance Act  being passed, it has been allowed that UK corporation tax (CT) and some other taxes may be allowed as deductions from the amount of DPT calculated as due. 
  • HMRC (the UK's tax authority) has drafted in from other of its  departments over 40 of its  international transfer pricing experts to raise the new tax.
  • Amazon (its EU HQ is based in Luxembourg) has announced that it is now recording revenues in each of its subsidiaries rather than in Luxembourg.
  • UK corporation tax is at a record low of 20%. It will reduce again to 19% in 2018 and then again to 18% in 2020.

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