Market leading insight for tax experts
View online issue

Finance Bill 2022: DPT amendments

printer Mail

Finance Bill 2022 is due to be considered by a Committee of the Whole House on 1 December 2021, before remaining clauses are passed to a Public Bill Committee (which is expected to begin its scrutiny of the Bill on 14 December). As set out in the ‘programme motion’ at Second Reading on 16 November 2021, the Public Bill Committee will finish its work by 13 January 2022.

At Second Reading, an amended Resolution 24 was agreed on closure notices in the context of the diverted profits tax (DPT). The government has also now proposed an amendment to clause 28 to the Bill (which will enact Resolution 24) for consideration on 1 December.

The changes are intended to prevent corporation tax closure notices from being given in all cases in the diverted profits tax review period. The original version of clause 28 provided that the prohibition on closure notices applied in relation to enquiries into company tax returns for accounting periods in respect of which a DPT charging notice has been issued. The new version extends the prohibition also to enquiries into any tax returns for avoided permanent establishments (as that term is used in FA 2015 s 86) that may be amended by the foreign company that has received the charging notice in order to reduce its diverted profits.

Written evidence submissions on the Finance Bill can be made direct via, up to the point when the Public Bill Committee finishes its work (early submission is ‘strongly advised’).

Issue: 1555
Categories: News