INTM489816 | Diverted Profits Tax: application of Diverted Profits Tax: examples and particular situations: Lloyd’s

The commencement provisions in section 116(4) Finance Act 2015 ensure that Lloyd’s members are subject to DPT on profits declared in the 2015 calendar year and subsequent periods. DPT only applies to profits referable to periods from 1 April 2015.

The 2013 year of account will include profits from 2013, 2014 and 2015. The DPT provisions do not apply to profits referable to times before 1 April 2015, that is, profits from 2013, 2014 and 1 January 2015 to 31 March 2015. Profits referable from 1 April 2015 are within scope of DPT.

DPT may apply to a year of account prior to 2013 if the year of account is in run off and there are profits referable to times on or after 1 April 2015.

Profits within the scope of DPT of a year of account are allocated to each period on a just and reasonable basis