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HMRC internal manual

International Manual

Controlled Foreign Companies carrying on general insurance business: Amendment of return where dividend not paid

SI1999/1408 Regulation 6 S

Where a United Kingdom company has made a return on the basis that a controlled foreign company will pay an acceptable distribution within 18 months of the close of the underwriting year and the company fails to do so, then the UK company must amend its return in respect of the relevant accounting period within 18 months and 30 days following the close of the underwriting year. Where the company fails to make the amendment within the period a tax-related penalty is due under FA98/SCH18/PARA20.