D4.445 Administration of the CFC regime
Scope of the CFC charge
The CFC charge is treated as though it were an amount of corporation tax and therefore all enactments which apply generally to corporation tax also apply to the CFC charge. This includes enactments relating to returns, account statements and reports, assessment, collection and receipt of corporation tax, rights of appeal, penalties, interest on unpaid tax and priority of tax in insolvency cases1.
Collection of the tax arising
Where the CFC charge is not fully paid on the date it is due and payable, HMRC can give notice of liability to another UK resident company when it holds or has held (directly or indirectly) the whole or any part of the same interest in the CFC concerned as is, or was, held by the defaulting company. If any sum remains unpaid after three months of such a notice, the outstanding amount may be recovered from the original defaulting company and/or the company on which notice has been served2.
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 14:04