In both cases, there is a requirement that there be activity (people) in the UK. The
rules are focused on profit that would have arisen in the UK if the arrangements
had not been implemented, and is not intended to bring within the charge to UK
tax activities carried on by persons in other countries. Broadly speaking, a tax
advantage will be deemed to arise where the overseas tax is less than 80% of the
UK tax that would have applied. Income taxed in high tax countries will not be
subject to the DPT.
An exemption from the DPT will apply in th