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HMRC internal manual

International Manual

Controlled Foreign Companies: legislation - introduction and outline: Interest and penalties

Interest is chargeable in the normal way on any tax paid late. A penalty may also be also due if the company makes an inaccurate return in respect of controlled foreign company matters. Where penalties are charged, they may be reduced in line with the usual criteria applied by HMRC in penalty cases. To ensure that the provisions are applied consistently no penalty may be applied without the approval of Business, Assets & International Base Protection Policy team. Further details are available at INTM256680, and there is more general information about penalties in the Compliance Handbook.