INTM214110 - How the CTSA regime works for Controlled Foreign Companies

Notice of liability

Where ICTA88/S747 tax is chargeable on a company (the chargeable company) and not paid before the due and payable date, the Board may serve a notice of liability on another company (the responsible company) resident in the United Kingdom which holds or has held either directly or indirectly the same interest as is or was held by the chargeable company in the controlled foreign company. The ICTA88/S747 tax, or so much of it as has not been paid, is then payable on service of that notice.

The responsible company on whom the notice has been served is also liable for any interest due on the unpaid ICTA88/S747 tax as well as interest accruing after the date of service of the notice.

Where a notice has been served on the responsible company and tax and interest remains unpaid three months after the service of the notice, the tax and interest may be recovered from the chargeable company despite the issue of a notice to the responsible company.