Commentary

D4.447 CFC appeals and penalties

Corporate tax
Corporate tax | Commentary

D4.447 CFC appeals and penalties

Corporate tax | Commentary

D4.447 CFC appeals and penalties

CFC appeals

An appeal against an HMRC amendment to a return or against a discovery assessment1 involving CFC tax is heard by the First-tier tribunal.

If the appeal involves a question likely to affect the liability to CFC tax of more than one person, each of those persons is entitled to appear and be heard or to make representations in writing. The question must then be determined separately from any other matters in the appeal and a decision on that question is binding on all the persons concerned.

Where HMRC enquire into a return, an appeal may

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