Intm245600 - controlled foreign companies: management and collection of a cfc charge and reliefs available against a cfc charge: recovery of sum charged from other uk resident companies - hmrc internal manual

INTM245600 - CONTROLLED FOREIGN COMPANIES: MANAGEMENT AND COLLECTION OF A CFC CHARGE AND RELIEFS AVAILABLE AGAINST A CFC CHARGE: RECOVERY OF SUM CHARGED FROM OTHER UK RESIDENT COMPANIES

RECOVERY OF SUM CHARGED FROM OTHER UK RESIDENT COMPANIES TIOPA10/S371UF applies if a sum charged on a company (the defaulting company) under step 5 of TIOPA10/S371BC(1) is not fully paid at

the due and payable date under the Taxes Acts. It allows an officer of HMRC to give notice of liability to another UK company, which holds, or has held (directly or indirectly) the whole or

any part of the same interest (the corresponding part) in the CFC concerned as is or was held by the defaulting company. On issue of a notice to this company (the responsible company) the

following are payable by the responsible company: * the whole or corresponding part of the sum charged that remains unpaid at the time the notice is given, * the whole or corresponding part

of any unpaid interest due on the sum charged at the time the notice is given, and * any interest accruing on the sum charged after the notice is given, as far as it is referable to the sum

payable by the responsible company under the issue of the notice. If any sum payable by the responsible company under TIOPA10/S371UF(3) is not fully paid by the end of three months, starting

with the date on which the notice is given, the outstanding amount may be recovered from the defaulting company. This does not however affect the right of recovery from the responsible

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