PART 1Income tax, corporation tax and capital gains tax
International matters
27Application of section 124 of TIOPA 2010 in relation to diverted profits tax
1
In Part 3 of FA 2015 (diverted profits tax) before section 115 (but after the heading “Final provisions”) insert—
114AApplication of section 124 of TIOPA 2010 in relation to diverted profits tax
A solution or mutual agreement mentioned in subsection (1)(b) of section 124 of TIOPA 2010 (giving effect to solutions to cases and mutual agreements resolving cases) may include provision related to diverted profits tax (and, accordingly, the duty in subsection (2) of that section includes a duty to make any such adjustment as is appropriate in relation to diverted profits tax).
2
In section 124 of TIOPA 2010 (giving effect to solutions to cases and mutual agreements resolving cases), after subsection (4) insert—
5
See section 114A of FA 2015 for provision applying this section in relation to diverted profits tax.
3
The amendments made by this section apply in relation to solutions arrived at, or mutual agreements made, by the Commissioners on or after 27 October 2021.