{"url":"https://lrlabs.ai/t/uk_avoided_pe_dpt_utpp_split","engine":"deterministic","llm_in_path":false,"id":"uk_avoided_pe_dpt_utpp_split","question":"Does UK Diverted Profits Tax still apply to an avoided-PE arrangement?","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 For periods beginning on or after 1 January 2026 DPT is repealed and the avoided-PE charge survives as Unassessed Transfer Pricing Profits (FA 2026 Sch 5), levied within corporation tax at 31%.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.","pinpoint":"FA 2015 ss.86-87 (to 31 Dec 2025); FA 2026 Sch 5 (from 1 Jan 2026)","confidence":"settled","as_at":"14 Aug 2026","value":31}