INTM489690 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: section 87 - exception for limited UK-related sales or expenses
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UK-related sales
In order to focus the operation of section 86 (“avoidance of a UK taxable presence”) on situations where there is a substantial level of economic activity in the UK there is an exception based on the level of a foreign company’s sales that are related to activity in the UK. Where those sales revenues of the foreign company taken together with certain sales revenues of connected companies are no more than £10 million in a 12-month accounting period, section 86 cannot apply.