INTM215270 - Controlled Foreign Companies: before CTSA

Notice of declaration: capital allowances - appeal against declaration

Companies can appeal against a declaration included in a notice of direction. They can do this under ICTA88/S753 (4)(d). The grounds are that the notice does not comply with the rule in ICTA88/SCH24/PARA11 (5) for making the declaration. In other words, the company meets one or more of the statutory exclusions for the accounting period for which the Board makes the declaration.

See INTM215190 for guidance on issuing notices of declaration.