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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: notification

INTM489860 | Diverted Profits Tax: customer engagement with HMRC: notification

From HM Revenue & Customs · International Manual

Guidance on the notification requirement is set out in INTM489880, with the recommended procedure and template provided at INTM489996 and INTM489998. Where a company notifies its potential liability to DPT directly to the CCM or case team the details should be passed to the DPT Unit and the designated HMRC officer. Case workers and CCMs should acknowledge receipt of the information but must not offer any further response until the DPT Unit has confirmed to them in writing how to proceed.

Where there is no existing engagement with a company HMRC will not, as a matter of course, respond to a DPT notification. Therefore, if a customer has notified potential liability to DPT but concluded that there is no DPT to pay and has not heard from HMRC, the customer cannot assume that HMRC agrees with their view that they are not within the scope of DPT.

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