[ compiled answer ]
law as at 14 Aug 2026 · settled
Does UK Diverted Profits Tax still apply to an avoided-PE arrangement?
The compiled answer
Split by accounting period: DPT (FA 2015 ss.86-87, 31%; 25% before April 2023) governs accounting periods beginning BEFORE 1 January 2026 only. For periods beginning on or after 1 January 2026 DPT is repealed and the avoided-PE charge survives as Unassessed Transfer Pricing Profits (FA 2026 Sch 5), levied within corporation tax at 31%. Citing DPT for a 2026-onwards period is a temporal error.
compiled value: 31
Pinpoint
FA 2015 ss.86-87 (to 31 Dec 2025); FA 2026 Sch 5 (from 1 Jan 2026)
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/uk_avoided_pe_dpt_utpp_split.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)