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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: EEA states - deduction for net economic value against apportionment: Timing of new rules

These rules apply from 6 December, the date of PBR 2006.

The legislation applies in relation to controlled foreign company accounting periods starting on or after 6 December 2006, or where an accounting period straddles that date, in relation to that part of the controlled foreign company’s accounting period running from 6 December 2006.

Applications must be made by the filing date for the UK Company’s tax return to which it is relevant. The company can only make its return on the basis of the application once the application has been granted. If a company has made its return before the application is granted, then the company will have 30 days after the grant of the application to amend its return to take account of its effect.

INTM256090 explains what information should be included in an application and where to send it to.