INTM214100 - How the CTSA regime works for Controlled Foreign Companies

Appeals

Special Commissioners - ICTA88/S754(3)

An appeal which involves a question concerning the application of Chapter IV under

• FA98/SCH18/PARA34(3) against an amendment to a return, or
• FA98/SCH18/PARA48 against a discovery assessment or discovery determination

is to be heard by the Special Commissioners.

Where any appeal under the above legislation is to be determined by the Special Commissioners and the resolution of the question is likely to affect the liability under Chapter IV of more than one person, then each of those persons concerned is entitled to appear and be heard by the Special Commissioners or to make written representations to them.

The Special Commissioners must then determine that particular question separately from any other question in those proceedings and their determination on that question shall have effect as if it were made in an appeal to which each of those persons was a party.