Taxation (International and Other Provisions) Act 2010 section 371UA

Introduction to Chapter

Section 371UA introduces the administrative framework for collecting and managing the controlled foreign company (CFC) charge, and defines key terms used throughout the chapter.

  • HMRC Commissioners are responsible for managing the CFC charge, including collecting the amounts charged.
  • A "closure notice" is a formal notice issued by HMRC when it completes an enquiry into a company's tax return and states its conclusions.
  • A "discovery assessment" is an assessment or determination made by HMRC when it discovers that tax has been underpaid, including assessments relating to fraudulent or negligent conduct.
  • The expression "the Taxes Acts" carries the same meaning as it does in the Taxes Management Act 1970, broadly covering the main body of UK tax legislation.

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