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HMRC internal manual

International Manual

Controlled Foreign Companies: How the corporate tax regime works for CFCs: Clearances: Where to send applications

Clearances: Where to send applications

All CFC applications and supporting documentation such as accounts should be sent electronically to Michael Paterson and copied to the UK group’s CCM. No hard copies of an application are required. If the UK group does not have an e-mail protocol with HMRC or if there has been no previous UK presence (for example when a foreign group is migrating its headquarters into the UK); it will be necessary to indicate in the application that the group or company is content to receive any reply electronically. Otherwise a reply will be sent by hard copy.

If it is not possible to send applications for clearance electronically, applications should be sent to the following address:

Business Assets & International, Base Protection Policy (CFC clearances)
10 South Colonnade

Canary Wharf


NE98 1ZZ


The clearances will be reviewed by members of the CFC clearances team within Business Assets & International. The review will aim to be dealt with within the normal HMRC turnaround time of 28 working days but, if further information is required in order to fully consider the application, then a fresh turnaround time of up to 28 days will apply from the time the further information is provided.

It is possible that applications involving novel or complex issues will need more time to facilitate detailed discussion and this may involve ongoing correspondence and meetings before resolution. If this is the case, it is likely that the CCM and tax specialists assigned to the case will be involved as well as the CFC clearance team. In all cases however comments on the application will be welcomed from the CCM or the case team.

The response to the clearance application will be sent electronically via the CCM. This ensures they are aware of what has and hasn’t been agreed. The CCM will provide a hard copy if required.