Penny Simmons
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.
Practice Area
Panel
- Contributing Author
Qualified Year
- 2006
Membership
- Law Society
Education
- The College of Law (Distinction, LPC)
- University of Manchester (First Class honours, BA Accounting and Law)
2 Contributions by Penny Simmons
PRACTICE NOTES
UK Diverted Profits Tax (DPT): notifications, preliminary/charging notices, review and appeal process, interest and penalties, PDCF and treaty interaction—archived guidance following repeal from 2026
ARCHIVED :
This archived Practice Note summarises the Diverted Profits Tax (DPT) regime, which was repealed for accounting periods beginning on or after 1 January 2026. DPT applied to periods starting between 1 April 2015 and 31 December 2025. It has been replaced by the unassessed transfer pricing profits (UTPP) rules set out in Schedule 5 to the Finance Act 2026. This Practice Note is not maintained and is provided for background only.
The DPT provisions are found in Part 3 and Schedule 16 to the Finance Act 2015. The legislation introduced a tax designed to deter avoidance of UK tax by multinational groups operating in the UK. DPT features distinct rules on notification, assessment and payment, and, unlike corporation tax, it is not self-assessed. This Practice Note considers compliance and administration issues arising from the regime, including:
company notification requirements
the preliminary notice
the charging notice
reviews, amending notices, supplementary charging notices and appeals
interest and penalties
clearances
interaction of DPT with tax treaties
For a fuller discussion of the two circumstances...
Tax
PRACTICE NOTES
United Kingdom Diverted Profits Tax (2015–2025): Charge to Tax, Lacking Economic Substance and Avoided Permanent Establishment Rules, Computation and Exceptions [Archived; repealed from 2026]
ARCHIVED :
This archived Practice Note sets out details of the Diverted Profits Tax (DPT) regime, which was repealed with effect for accounting periods beginning on or after 1 January 2026. DPT applied to accounting periods beginning between 1 April 2015 and 31 December 2025. The regime has been replaced by the unassessed transfer pricing profits (UTPP) rules, as set out in Schedule 5 to the Finance Act 2026. This Practice Note is not maintained and is supplied for background purposes only. The DPT provisions are contained in Part 3 of the Finance Act 2015. The legislation establishes a tax intended to deter the avoidance of UK tax by multinationals operating in the UK. The introduction of DPT was first signalled in the Autumn Statement 2014. Note that DPT is a separate tax and is not corporation tax. In overview, DPT applies in two situations:
entities or transactions without economic substance—where a group of companies has a UK subsidiary or a permanent establishment (PE) and connected parties put in place arrangements that ‘lack economic substance’ in order to exploit tax mismatches; an example would be profits being extracted from a UK subsidiary...
Tax
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