INTM215540 - Controlled Foreign Companies: before CTSA

Losses: pre-direction losses - time limit for claim

The company must claim within sixty days of the date of the notice of direction for the starting period. The Board may allow more time. The claim must be made by the United Kingdom company or companies having a majority interest - see INTM209120 - in the company for the starting period. The Inspector can normally allow a late claim. The Inspector can do this if the company makes the claim before the chargeable profits for the 'starting period' are finally determined, either in the absence, or by the settlement, of an appeal.