INTM215550 - Controlled Foreign Companies: before CTSA

Reports and submissions to Business International, Outward Investment team

A formal report to Business International, Outward Investment team for periods prior to the introduction of corporate tax self assessment is required when the case is settled and

• the tax is assessed or
• there is a result in favour of HM Revenue & Customs. A company might, for example, pay an acceptable dividend or wind up its company in the low tax territory, or
• the Inspector has had to agree that there is no tax due but feels that Chapter IV ought to have applied

Reports or submissions are also required for periods prior to the introduction of corporate tax self assessment in the following cases:

• where the Board is being asked to consider exercising its information powers INTM215080 
• where the Board is being asked to consider making a direction INTM215200 
• where a company requests that Board direct that it need not comply with a notice under ICTA88/S755 (3) INTM215050 
• where the Inspector finds out that the accounting period specified in a notice of direction is wrong INTM215130 
• where the Inspector receives an appeal for a case which is with Business International, Outward Investment team INTM215160 (and also see INTM215390)
• where the Inspector receives appeals from unconnected parties INTM215170 
• where the Inspector needs a form CT14(Z) Revision to notify a revision of chargeable profits or creditable tax INTM215230 
• where the Inspector identifies a case which may be suitable for a declaration under ICTA88/SCH24/PARA11 (3) INTM215260 
• where the Inspector recommends a particular method of apportionment - this will normally be covered within the report mentioned at INTM215200 
• where a late disclaimer is submitted which may increase the liability of a person not party to the disclaimer INTM215480