INTM489878 | Diverted Profits Tax: customer engagement with HMRC: Diverted Profits Tax and Treaties

As a separate and distinct tax DPT is outside of double taxation treaties. Also, DPT is targeted at contrived tax avoidance arrangements which seek to abuse the provisions of the United Kingdom’s tax treaties, so there would be no obligation to give relief under a double taxation treaty for such arrangements.

DPT has its own provisions (see INTM489948) for giving relief for foreign tax paid.