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Clifford Chance

Clifford Chance


The Diverted Profits Tax (DPT) – an update

14 August 2019

Part 3 of the Finance Act 2015 (FA 2015) introduced an entirely new tax on cross-border businesses and transactions. Four years later, the diverted profits tax (DPT) remains largely unique amongst national tax codes, with Australia the only other country to have followed the UK’s approach. Commentators—the writer included—who at the time expressed concern at the DPT’s radical scope, complexity, and “hair-trigger” conditions, would have been forgiven for thinking that the actual impact of the DPT would become clear within a few years. This has notably not been the case.

This article updates our commentary with the latest amendments to the DPT and the outlook for gaining a better understanding of the tax in the coming years.

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