PART 3Diverted profits tax
Calculation of taxable diverted profits: section 86 cases
90Section 86: mismatch condition is met: calculation of profits by reference to the actual provision
1
This section applies where—
a
section 86 applies for an accounting period,
b
the mismatch condition is met, and
c
the actual provision condition is met.
2
The taxable diverted profits that arise to the foreign company in the accounting period, in relation to the material provision in question, are an amount equal to the notional PE profits for that period.