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HMRC internal manual

International Manual

HM Revenue & Customs
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Controlled Foreign Companies: Reviews: Working individual companies

An enquiry will generally begin with the entries on the supplementary page to the return for controlled foreign companies. It is the immediate United Kingdom company holding the interest in the controlled foreign company that will complete the group’s supplementary page for controlled foreign companies.

HMRC will, in all likelihood, already hold information on controlled foreign companies within the group which will provide useful background during a review. If, for example, there are no entries on a return that would be expected from this information the Officer may wish to enquire into the reasons behind this. (Remember, however, that controlled foreign companies which satisfy the excluded countries regulations need not be included on a return). It would also be advisable to ascertain that the facts have not changed since any clearances were given. One would also expect a review to confirm that exemptions claimed were properly due.

It is quite possible that an entry on the return will be the first time that the Officer will be aware that a company or group has an interest in a Controlled Foreign Companies, since no enquiries may have been made in earlier years and the group may not have volunteered the information. In such cases the Officer will need to consider whether liability exists for earlier years. Business International, Outward Investment Team can advise here.