LONDON – Accountancy/shipping advisory specialist Moore Stephens claims companies in the offshore maritime sector could be affected by the UK’s proposed 25% Diverted Profits Tax (DPT) charge.
Under the draft legislation published by the UK government last December, and due to become law this April, the charge could apply to many UK companies in the offshore sector transacting with overseas connected parties.
It could include a UK company that leases equipment from an overseas-connected company based in a low-tax jurisdiction, in which case the transaction could be deemed as an attempt to secure a reduction in the UK company’s corporation tax liability.
The UK Tax Office (Her Majesty’s Revenue & Customs) has said that further consideration should be given to the interaction of these new rules with the cap on bareboat charter payments made to an associate by a company working on the UK continental shelf (UKCS). It is not clear, however, whether these rules will be modified for companies working on the UKCS, Moore Stephens point out.