INTM215340 - Controlled Foreign Companies: before CTSA

Apportionment: appeals

ICTA88/S754 (3) and TMA70/S31

A company can appeal against a Chapter IV assessment on chargeable profits. The grounds of the appeal may be the way the Board apportions those profits or the creditable tax. The Special Commissioners can review the basis of apportionment. They can replace it with their own decision if they see fit.