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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: Assumed Taxable Total Profits, Assumed Total Profits and the Corporation Tax Assumptions: Double Taxation Relief - Counteraction Notices

TIOPA10/Part 9A/S371SR ensures that the double tax relief anti avoidance provisions within TIOPA10/S82 apply in computing the creditable tax of a CFC. These rules ordinarily require a notice to be issued by an officer of HMRC and so the rule applies by assuming that such a notice has been issued.