INTM215380 - Controlled Foreign Companies: before CTSA

Assessment: matters to be included in assessment

ICTA88/S754 (2)

A notice of assessment under Chapter IV must show the detail below. (This is besides the other matters that the Inspector must include in a notice of assessment).

• The total amount of chargeable profits and creditable tax apportioned to each separate category of person. These are persons with an interest in the controlled foreign company under ICTA88/S749 (5) and (7).
• The total amount apportioned to persons holding shares of each class. This is where there is more than one class of shares in the controlled foreign company.

The notice must show the amount of chargeable profits etc apportioned to each category of persons with an interest. It must not show details for persons other than the recipient of the notice. This restriction is to protect the confidentiality of taxpayers' affairs.