The manner in which adjustments may be required under the legislation is broad1.HMRC guidance sets out the usual content and timing of notices2.
Prior to there repeal by FA 2018, there were detailed provisions in TIOPA 2010, ss 89–95 covering the format, timing and consequences of counteraction notices, and the HMRC guidance is broadly modelled on these previous rules. HMRC guidance sets out that a counteraction notice should set out HMRC's view that the legislation applies and the chargeable period for which it applies. If underlying tax is involved, the notice should also state the body corporate whose payment of foreign tax is relevant to the underlying tax. The taxpayer may dispute whether the
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