INTM215350 - Controlled Foreign Companies: before CTSA

Apportionment: matters to be included in a report to CT & VAT, International CT

There are cases where the Inspector needs to make a report under INTM215200 for the issue of a Board's direction under Chapter IV. The Inspector should say in this report to whom the Inspector thinks the Board should apportion the chargeable profits etc of the controlled foreign company. The rules in INTM215300 and INTM215310 provide guidance on this.

The Inspector may have a case where the Inspector think that a person exercises control or rights over a controlled foreign company by means other than ordinary share capital. The Inspector may in that case consider that the other methods of apportionment set out in INTM215310 are in point. If so, details should be given in the report.

More than one United Kingdom company may hold the same interest in a controlled foreign company. This could be, for example, as described in INTM215320. In such cases the Inspector should say in the report

• which of the companies is the 'assessable company' in accordance with (a) to (c) of INTM215320, and
• the names of all the other United Kingdom companies that hold the same interest as the 'assessable company'.