On 31 December 2018, UK HMRC published updated guidance on the Diverted Profits Tax (DPT). The DPT was introduced in the UK Finance Act 2015 and generally applies from 1 April 2015. The normal rate of DPT is 25% of the diverted profit plus any true-up interest, which is imposed on large groups that either: Seek to avoid creating a UK permanent establishment that would bring a foreign company into the charge to UK Corporation Tax; or Use arrangements or entities that lack economic substance to exploit tax mismatches either through expenditure or the diversion of income within the group....