There are two steps to take when a charge is made under Chapter
IV.
A notice is issued that the Board is making a direction. This
goes to each United Kingdom resident company with an interest in
the controlled foreign company concerned.
A notice of assessment is issued. This goes to each United
Kingdom company liable to tax on the controlled foreign company's
chargeable profits.
There is a distinction between the direction and assessment.
The direction includes matters that are of common concern to
the United Kingdom companies.
The assessment, on the other hand, relates to matters of
concern to the individual companies.
An example of common concern is the existence of a controlled
foreign company. So is the amount of chargeable profits. A matter
of individual concern is the amount of chargeable profits the
Inspector apportions to individual companies and their claims to
reliefs.
The direction and the assessment are kept apart to preserve
confidentiality.
Further detail on notices of direction is given in the
following pages:
| INTM215100 | Notice of direction: can a direction be made? |
| INTM215110 | Notice of direction: matters to be included |
| INTM215120 | Notice of direction: residence in more than one territory |
| INTM215130 | Notice of direction: amendments to a notice of direction |
| INTM215140 | Notice of direction: revision of chargeable profits or creditable tax |
| INTM215150 | Notice of direction: appeals – right of appeal against a notice of direction |
| INTM215160 | Notice of direction: appeals – responsibilities of Inspector |
| INTM215170 | Notice of direction: appeals – appeals from unconnected parties |
| INTM215180 | Notice of direction: appeals – regulations concerning appeals |
| INTM215190 | Notice of direction: separate notice of declaration |
| INTM215200 | Notice of direction: report for Board's direction |
| INTM215210 | Notice of direction: procedure following making of direction |
| INTM215220 | Notice of direction: procedure following amendment to direction |
| INTM215230 | Notice of direction: procedure following revision to chargeable profits or creditable tax |
| INTM215240 | Notice of direction and notice of assessment: forms |
