On 30 November 2015, UK HMRC published updated guidance on the Diverted Profits Tax (DPT). The 25% DPT was introduced in the UK Finance Act 2015, which received Royal Assent on 26 March 2015, and applies for profits arising from 1 April 2015 ({News-2015-03-25/A/2- previous coverage}). The DPT is levied on profits derived from the UK by large groups that either:
- Seek to avoid creating a UK permanent establishment that would bring a foreign company into the charge to UK Corporation Tax, or
- Us…