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HMRC internal manual

International Manual

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Notice of liability

Where a CFC charge is chargeable on a company (the chargeable company) and not paid before the due and payable date, an officer of HM Revenue & Customs may serve a notice of liability on another company (the responsible company) resident in the United Kingdom which holds or has held either directly or indirectly the same interest as is, or was, held by the chargeable company in the CFC. The CFC tax, or so much of it as has not been paid, is then payable on service of that notice.

The responsible company on whom the notice has been served is also liable for any interest due on the unpaid CFC tax as well as interest accruing after the date of service of the notice.

Where a notice has been served on the responsible company and tax and interest remains unpaid three months after the service of the notice, the tax and interest may be recovered from the chargeable company despite the issue of a notice to the responsible company.