At Autumn Budget 2018 HMRC issued a policy paper, Diverted profits tax amendments. This announced some amendments to the DPT legislation, subsequently enacted by Finance Act 2019 (FA 2019). The amendments:

• changed the manner of calculation of taxable diverted profits (for accounting periods beginning on or after 29 October 2018), and extended the time for issuing a preliminary notice (in cases where the previous deadline had not expired by Royal Assent), in Finance Act 2015, s82–85, 88, 93. This was to close a loophole, whereby amendments could be made to a company’s corporation tax return after the review period had ended and DPT time limits had expired;

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