INTM489755 - Diverted Profits Tax: application of Diverted Profits Tax: legislation 바카라 사이트“ Finance Act 2015 바카라 사이트“ core provisions: the effective tax mismatch outcome 바카라 사이트“ 80% payment test
This test ensures that the legislation applies only if the tax reduction resulting from the material provision is substantial. It is met (that is, there is no effective tax mismatch outcome) if the increase in the second party바카라 사이트™s liability to relevant taxes is at least 80% of the reduction in the amount of relevant tax payable by the first party.