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HMRC internal manual

International Manual

Controlled Foreign Companies: Computation of Chargeable Profits and Creditable Tax: Time limit

ICTA88/SCH24/PARA4(2)

A notice disclaiming reliefs which a company is assumed to have claimed has to be given within 20 months following the end of the accounting period of the controlled foreign company or within such longer period as the Commissioners of HM Revenue & Customs may, in any particular case, allow. Time limits will be extended where there are difficulties outside the power of the United Kingdom interest or interests in obtaining sufficient information to decide that a disclaimer is worthwhile.