INTM489735 - Diverted Profits Tax: application of Diverted Profits Tax: legislation � Finance Act 2015 � core provisions: the participation condition B - non-financing arrangements

»Ê¹ÚÌåÓýapp condition is met if at the time of making or imposing the material provision

  • one of the relevant parties was directly or indirectly participating in the management, control or capital of the other, or
  • the same person or persons was or were directly or indirectly participating in the management, control or capital of each of the relevant persons.

»Ê¹ÚÌåÓýapp detail of the meaning of “direct participationâ€� and “indirect participationâ€� is given at sections 157 to 163 TIOPA 2010 (see INTM412060) and the relevant elements of these sections are brought into the DPT rules.