INTM489670 - Diverted Profits Tax: application of Diverted Profits Tax: legislation � Finance Act 2015 � core provisions: section 86 exceptions � SMEs

Section 86 will not apply where the avoided PE and the foreign company are both SMEs. »Ê¹ÚÌåÓýapp same definitions are used as in section 80 â€� see INTM489595.