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HMRC internal manual

Company Taxation Manual

Residence: dual resident companies: Board's direction

The attribution rules of ICTA88/SCH17/PARA5 and 6, which applied in priority to the apportionment rules of ICTA88/SCH17/PARA1 (3), could only be activated by a direction from the Board. Dual resident investing companies had 60 days in which to appeal against such a direction (ICTA88/SCH17/PARA7).

Apply if necessary to CTIS (Technical) for archive guidance. See CTM34700.