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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: Appeals affecting more than one person.

If there is an appeal under paragraphs 34(3) or 48 Schedule 18 FA 1998 against the amendment of a tax return or discovery assessment, involving any question concerning the application of TIOPA10/Part 9A in relation to a particular person and the resolution of that question is likely to affect the liability under Part 9A of any other person in relation to the CFC concerned, section 371UE dictates the conduct of the appeal. Note, this is not limited to chargeable companies as defined for the purposes of Part 9A.

Each person likely to be affected by the determination of the appeal is entitled to be a party to the proceedings. The tribunal must determine the question separately from any other question in the proceedings and the tribunal’s determination shall be treated as if it were made in an appeal to which each affected person was a party.