Controlled Foreign Companies: legislation - introduction and outline: Board’s notice of approval and rights of appeal
Before an Officer formally proposes an adjustment to a self assessment he or she must first obtain the Commissioners of Revenue & Customs’ written approval. See INTM256660 - Enquiries: Commissioners’ Sanction and INTM256830 - Reports to Business International: Outward Investment Team.
Any appeal against the application of the legislation is to the First-tier Tax Tribunal. Further details are found in INTM256700.