INTM489665 - Diverted Profits Tax: application of Diverted Profits Tax: legislation – Finance Act 2015 – core provisions: section 86 exceptions – companies with limited UK related sales or expenses

There is also an exception at section 87 where:

• the foreign company’s total UK-related sales revenues (subject to conditions in relation to those of connected companies) in a 12-month accounting period are no greater than £10 million; and/or
• the foreign company’s total UK-related expenses (subject to conditions in relation to those of connected companies) in a 12-month accounting period are no greater than £1 million.

If the accounting period is shorter the thresholds are reduced proportionately. This exception is discussed in more detail at INTM489690.