INTM489900 | Diverted Profits Tax: notification, charging and payment: raising a Diverted Profits Tax charge – overview

There is a flowchart outlining the end-to-end process for raising a DPT charge at INTM489884.

Before a charging notice can be issued, HMRC must send the company a preliminary notice explaining how the charge is calculated and who must pay it. Having been issued with a preliminary notice, the company may make representations to HMRC but the representations which HMRC must consider at this stage are limited to certain specified issues.

Once the period within which representations may be made has expired, a designated HMRC officer may bring DPT into charge by issuing a charging notice.

The charge to tax will include an interest element (“true up interest”) on the DPT, running from 6 months after the end of the accounting period to the date the charging notice is issued.

DPT must be paid within 30 days from the issue of the charging notice and there is no right to postpone the liability to tax.

There is a 15-month period beginning immediately after the date by which the tax must paid (the “review period”) for HMRC to review the charging notice and issue a supplementary notice or amending notices increasing or reducing the DPT. Any overpaid DPT must be repaid in accordance with HMRC’s tax accounting and set-off policies.

The company has 30 days from the end of the review period to appeal or the DPT becomes final.