INTM215160 - Controlled Foreign Companies: before CTSA

Notice of direction: appeals - responsibilities of Inspector

Strictly, the company should make an appeal against a notice of direction to the Board.

In practice the Inspector may receive appeals against a notice of direction direct. This might happen, for example, when the Inspector receives an appeal against a direction at the same time as an appeal against a Chapter IV assessment.

The Inspector should endeavour to settle the appeal, reporting to CT & VAT, International CT when:

• the appeal is settled, or
• doubts or difficulties arise which the Inspector cannot resolve, or
• a formal hearing of the appeal before the Special Commissioners appears likely or necessary.

The Inspector should deal with appeals made after the sixty day time limit under TMA70/S49 as normal.

If the Inspector receives an appeal for a case which is at CT & VAT, International CT, it should be passed on immediately. And CT & VAT, International CT will immediately pass on any appeals received for a case which is being worked by an Inspector.