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HMRC internal manual

International Manual

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Appeals

First-tier Tribunal - TIOPA10/S371UE

An appeal which involves a question concerning the application of Part 9A under

  • FA98/SCH18/PARA34(3) against an amendment to a return, or
  • FA98/SCH18/PARA48 against a discovery assessment or discovery determination

is to be heard by the First-tier Tribunal.

Where any appeal under the above legislation is to be determined by the First-tier Tribunal and the resolution of the question is likely to affect the liability under Chapter IV of more than one person, then each of those persons concerned is entitled to appear and be heard by the First-tier Tribunal or to make written representations to them.

The First-tier Tribunal must then determine that particular question separately from any other question in those proceedings and their determination on that question shall have effect as if it were made in an appeal to which each of those persons was a party.