PART 3Diverted profits tax
Calculation of taxable diverted profits: section 86 cases
89Section 86: calculation of profits where only tax avoidance condition is met
(1)
This section applies where—
(a)
section 86 applies for an accounting period, and
(b)
the mismatch condition is not met.
(2)
The taxable diverted profits that arise to the foreign company in the accounting period by reason of that section applying are an amount equal to the notional PE profits for that period.