Clifford Chance

The UK diverted profits tax: final legislation published

25 March 2015

The Finance Bill to enact the "Google Tax" has been published today. Properly known as the diverted profits tax (DPT), once enacted, for the first time companies outside the UK could be subject to UK tax merely for doing business with the UK. The Government say the tax is aimed only at artificial and contrived arrangements – we think it is much wider.

How does the tax work and when will it apply? Will it tax only the companies it is aimed at? Or will ordinary commercial arrangements and transactions be caught in the crossfire? And is it compatible with EU law and the UK's double tax treaties?

Download PDF