Commentary

A6.1210 Types of investigation—company issues

Administration and compliance

A6.1210 Types of investigation—company issues

A6.1210 Types of investigation—company issues

Controlled foreign company (CFC) rules

Broadly where a non UK-resident company is controlled by a UK person and the tax it pays overseas is less than 75% of what it might have been in UK resident, then there may still be a tax liability in the UK, subject to various exemptions.

Under corporation tax self-assessment (CTSA)1, there is a requirement to include CFC charges in a supplementary page of the CTSA return, and the information supplied in the return will provide the starting point for any CFC enquiry. HMRC are entitled to enquire into entries in the supplementary page of the company's return as regards such a liability and to request such documents and information as

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial