INTM201170 - Controlled Foreign Companies: legislation - introduction and outline

Interest and penalties

Interest is chargeable in the normal way under self assessment on any tax paid late. A tax- geared penalty is also due if the company makes a fraudulent or negligent return in respect of controlled foreign company matters. Where penalties are charged, they will be mitigated in line with the usual criteria applied by the HM Revenue & Customs in penalty cases. To ensure that the provisions are applied consistently no penalty may be applied without the approval of Business International: Outward Investment Team. Further details are available at INTM214080.