INTM489987 - Diverted Profits Tax: imposing a charge – procedure and governance: supplementary charging notices and amending notices

INTM489880 contains detailed guidance on issuing supplementary charging notices and amending notices (see INTM489924 and INTM489926). During the review period HMRC can issue a supplementary charging notice if it considers that the amount of profits included in a charging notice for an accounting period is insufficient. HMRC can issue an amending notice if based upon the evidence the designated HMRC officer considers that the profits included in the original charging notice for an accounting period are excessive.

Where an amending notice is issued, any part of the tax paid against the original charging notice (or supplementary charging notice) that has become an overpayment is repaid with interest, provided that the tax charged by the earlier notice has been paid in full. The repayment will be in accordance with HMRC’s tax accounting and set-off policies.

Supplementary notices and the amending notices are issued by the designated HMRC officer. The case worker should send a report explaining the need for a supplementary or amending notice to the DPT Unit which will liaise with the designated HMRC officer.