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HMRC internal manual

International Manual

HM Revenue & Customs
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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.