INTM489920 | Diverted Profits Tax: notification, charging and payment: review period

Following the issue of the charging notice HMRC has a further period (the review period) in which it must review the charging notice and make amendments to reduce the amount of taxable diverted profits and the charge to DPT, if appropriate. HMRC may also issue a supplementary charging notice to impose an additional charge if more DPT needs to be brought into charge.

In carrying out the review, there are no limitations to the representations HMRC may consider and the special rules disallowing 30% of expenditure under the inflated expenses condition are disregarded. This means that through the review period, the amount of the DPT charge can be either increased or decreased based on due consideration of the evidence on the level of the adjustment to the relevant expenditure, as well as any other relevant matters.