INTM215470 - Controlled Foreign Companies: before CTSA

Reliefs to prevent double charge: dividends - 'wasted relief'

ICTA88/SCH26/PARA4(4) and (5)

See INTM211190 for detailed guidance on 'wasted relief'. This page provides guidance on the way in which a claim for such relief should be made for periods prior to the introduction of self assessment for companies.

For periods prior to the introduction of self assessment, the company should address the claim for 'wasted relief' on dividends paid by a controlled foreign company to the Inspector. The claim should state:

• the name of the claimant company
• the name of the controlled foreign company whose profits led to the Chapter IV tax
• the accounting period concerned, and
• the date of issue and reference number of the assessment on which the company paid tax.

The company should also give details of the dividend received which leads to the claim. If it has the relevant information, the company should send with the claim a computation of the gross attributable tax and the wasted relief.