INTM215070 - Controlled Foreign Companies: before CTSA

Information powers: information regarding third parties

There is only one reason for the powers in ICTA88/S755. It is to help get information from groups. This is only so that Chapter IV can be applied to the non-resident members of a group. The powers should never be used to get information about non-associated third parties. An example of a third party is an arm's length client of a controlled foreign company that operates in a low tax territory.