| 释义 |
diverted profits tax
A tax charged on profits of a company that have been artificially diverted from the charge to UK corporation tax (Finance Act 2015 ss 77–116, sch 16). The tax is, in principle, separate from corporation tax and is charged at a special rate of 25% on profits generated in the UK but attributed to an entity not charged (or not fully charged) to UK tax. The legislation refers to the charge arising where there is an “effective tax mismatch” or where profits are attributed to an overseas company with “insufficient economic substance”. Liability to diverted profits tax arises from a declaration by an officer of HM Revenue and Customs, but (controversially) there is a liability on a company to notify HMRC if it is potentially within the charge (s 92). This provision imports into the charge statutory penalties and interest charges. A small or medium-sized company (defined as a company whose turnover, aggregated with the turnover of any group companies, is less than £10 million) is not subject to diverted profits tax (s 87). |