In April 2015, the UK introduced diverted profits tax (DPT). The UK government presented DPT as a mechanism for countering perceived large scale tax avoidance by multinationals, particularly arrangements to divert taxable profits from the UK. The legislation is both complex and broadly worded, and potentially applies to a wide range of industries and operational structures. Two years on, we are now seeing the impact of DPT in practice, including the challenges faced by multinationals in understanding and applying the legislation, complying with notification requirements and responding to HMRC enquiries.