INTM489981 | Diverted Profits Tax: imposing a charge – procedure and governance: preliminary notice

The designated HMRC officer will issue a preliminary notice to a company if they have reason to believe that a DPT charge arises.

Before a notice is issued to a company the HMRC case team will set out the basis on which a preliminary notice should be issued and draft the preliminary notice. This will be passed to the DPT Unit which will consider it, liaise with other HMRC officers where necessary and, pass to senior officers who will make a recommendation for consideration by the designated HMRC officer.

The designated HMRC officer is an officer with an appropriate level of seniority who is authorised to sign and issue the preliminary notice.