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HMRC internal manual

International Manual

Controlled Foreign Companies: Management and collection of a CFC charge and reliefs available against a CFC charge: Introduction

TIOPA10/Part 9A/Chapter 21 sets out the framework provisions for collection and management matters relevant to the CFC rules. It also details what reliefs are available for set off against a CFC charge.

For the purposes of this Chapter:

  • “closure notice” means a notice under paragraph 32 of Schedule 18 to FA 1998 (completion of enquiry and statement of conclusions);
  • “discovery assessment” means a discovery assessment or discovery determination under paragraph 41 of Schedule 18 to FA 1998 (including an assessment by virtue of paragraph 52 of that Schedule), and
  • “the Taxes Acts” has the same meaning as in TMA 1970.