INTM489980 | Diverted Profits Tax: imposing a charge – procedure and governance: engagement during the review period

HMRC expects that customers will want to work collaboratively during the review period as they have to pay DPT upfront and will want to obtain certainty and have any excess DPT repaid. Although the company cannot postpone the DPT and must pay it in full, HMRC can issue amending notices during the review period to reduce the DPT charged and repay the resulting overpayment.

If a group does not collaborate with HMRC during the review period in regard to providing required information, the information can be sought using formal powers in Schedule 36 Finance Act 2008 (see INTM489940).