INTM489904 - Diverted Profits Tax: notification, charging and payment: issuing the preliminary notice

The preliminary notice is issued to the company believed to be within the scope of DPT and, in addition a copy must be issued to

• the UK permanent establishment of that company, where the company is non-UK resident and its UK permanent establishment is involved with entities or transactions lacking economic substance,
• the avoided PE in cases concerning a non-UK company avoiding a taxable presence.