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Contents

Official guidance
International Manual

INTM489830 · Diverted Profits Tax: customer engagement with HMRC

  • INTM489833 · Introduction
  • INTM489836 · Initial contact between customers and HMRC
  • INTM489839 · Diverted Profits Tax - internal advice and support network for case workers and CCMs
  • INTM489842 · Informal discussions between HMRC and customers
  • INTM489845 · Informal engagement about Diverted Profits Tax
  • INTM489848 · No formal statutory or non-statutory clearance procedure for Diverted Profits Tax
  • INTM489851 · What an initial informal discussion should cover
  • INTM489854 · Seeking information from other sources
  • INTM489857 · Detailed risk reviews – operational approach
  • INTM489860 · Notification
  • INTM489863 · Advance Pricing Agreements do not extend to Diverted Profits Tax
  • INTM489866 · How Advance Pricing Agreements in force at 1 April 2015 interact with Diverted Profits Tax
  • INTM489869 · Advance Pricing Agreements entered into after the introduction of Diverted Profits Tax
  • INTM489872 · Advance Pricing Agreements concluded for periods ending before 1 April 2015
  • INTM489875 · Diverted Profits Tax and Advance Thin Capitalisation Agreements
  • INTM489878 · Diverted Profits Tax and Treaties
  1. Diverted Profits Tax: customer engagement with HMRC: contents
  2. Diverted Profits Tax: customer engagement with HMRC: Diverted Profits Tax - internal advice and support network for case workers and CCMs

INTM489839 | Diverted Profits Tax: customer engagement with HMRC: Diverted Profits Tax - internal advice and support network for case workers and CCMs

From HM Revenue & Customs · International Manual

An internal advice and support network ensures that CCMs and case workers have a clear route to comprehensive guidance at all stages in dealing with DPT. This supports their engagement with customers and ensures that DPT is administered consistently and effectively. The network includes:

LB International Tax Specialists and MSB Diverted Profits Technical Co-ordinators

They provide case workers and CCMs with leadership on profit diversion issues and technical support on the application of DPT throughout both the risk assessment and working of the case. They can also provide case workers and CCMs with advice and support in relation to other international tax aspects such as transfer pricing or permanent establishments. They engage with the DPT Unit and, when necessary, with technical and policy specialists in Business, Assets and International as well as engaging with customers.

Diverted Profits Tax Unit (DPT Unit)

This is a team of operational specialists based in Large Business. They provide advice to case workers, LB International Tax Specialists and MSB Diverted Profits Technical Co-ordinators on the application of the DPT legislation. They also oversee the process of issuing DPT notices, supporting the designated HMRC officer and co-ordinating the governance process (further detail on governance is in INTM489976).

Designated HMRC officer

The designated HMRC officer has statutory responsibility under the DPT legislation for issuing preliminary notices, considering representations on the preliminary notice, issuing charging notices, estimating profits for preliminary and charging notices and carrying out the review of the charging notice, including any issue of supplementary charging notices or amending notices.

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