INTM215100 - Controlled Foreign Companies: before CTSA

Notice of direction: can a direction be made?

ICTA88/S750 (3)

The Inspector may need to determine whether the Board can make a direction for an accounting period. To do this the Inspector needs to work out the overseas company's chargeable profits and corresponding United Kingdom tax for that period. See INTM209030 under 'Assumed apportionment' for guidance on this working and for an example.

The Inspector should assume that the Board has:

• already made a direction for that period and
• made any declaration it could have under ICTA88/SCH24/PARA11 (3) - see INTM215260 and has given notice of this in writing.