Penny Simmons

Pinsent Masons

Penny is a Legal Director in the tax team at Pinsent Masons, specialising in tax risk management for large corporates. Penny also provides technical assistance to clients and members of the team on all areas of corporate tax including corporate finance and M&A work, private equity, employment tax and property tax.

Contributed to

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The Diverted Profits Tax—charge to tax

Practice notes

This Practice Note considers the two circumstances in which a charge to the Diverted Profits Tax (DPT) will arise. The circumstances are, first, where entities or transactions lack economic substance, and, second, where there is an avoidance of a UK taxable presence. It explains how the Effective Tax Mismatch Outcome (ETMO) and the Insufficient Economic Substance (IES) conditions work. The DPT provisions are included in Part 3 of the Finance Act 2015. DPT is aimed at preventing the avoidance of UK tax by large groups (typically multinational enterprises) that result in the erosion of the UK tax base. The DPT applies for accounting periods beginning on or after 1 April 2015. This Practice Note is produced in partnership with Penny Simmons of Pinsent Masons LLP.

Tax

The Diverted Profits Tax—compliance and administration

Practice notes

This Practice Note considers the specific rules for notification, assessment and payment of the Diverted Profits Tax (DPT). The DPT provisions are included in Part 3 of the Finance Act 2015. The legislation provides for a tax aimed at preventing the avoidance of UK tax by large groups (typically multinational enterprises) that result in the erosion of the UK tax base. The DPT applies for accounting periods beginning on or after 1 April 2015. This Practice Note is produced in partnership with Penny Simmons of Pinsent Masons LLP.

Tax