INTM489916 | Diverted Profits Tax: notification, charging and payment: who should be issued with the charging notice
From HM Revenue & Customs · International Manual
The charging notice is issued to the company liable to DPT and, in addition, a copy must be issued to
the UK permanent establishment of that company, where the company is non-UK resident and its UK permanent establishment is involved with entities or transactions lacking economic substance
the avoided PE in cases concerning a non-UK company avoiding a taxable presence.