Taxation (International and Other Provisions) Act 2010

[F1 Completion of enquiry U.K.

Textual Amendments

F1 Sch. 7A inserted (with effect in accordance with Sch. 5 para. 25(1)(2) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 2 (with Sch. 5 para. 28)

47 (1) An enquiry into an interest restriction return submitted by a reporting company is completed when an officer of Revenue and Customs by notice (a “closure notice”)— U.K.

(a) informs the company that the officer has completed the enquiry, and

(b) states the officer's conclusions.

(2) The closure notice takes effect when it is given.

(3) If an officer of Revenue and Customs concludes that the return should have been made for one or more different periods of account of the group, the closure notice must designate the period of account (or periods of account) for which the return should have been made.

(4) If an officer of Revenue and Customs concludes that an interest restriction return in relation to a worldwide group should have been submitted—

(a) in relation to one or more different worldwide groups, or

(b) in relation to a different membership,

the closure notice must designate each period of account of a worldwide group for which an interest restriction return should have been made or for which an interest restriction return should have been submitted in relation to a different membership.

(5) If the officer concludes that the group in relation to which the return was submitted has a different membership, the designation under sub-paragraph (4) must also include details of the members of the group that the officer considers are UK group companies.

(6) If the officer concludes that the return should have been submitted in relation to one or more different worldwide groups, the designation under sub-paragraph (4) must also include—

(a) sufficient details to identify the different worldwide group or groups, and

(b) details of the members of the group that the officer considers are UK group companies.

(7) A designation by a closure notice of a period of account under this paragraph must specify the dates on which the period of account begins and ends.

(8) In this paragraph references to UK group companies, in relation to a period of account, do not include UK group companies that are dormant throughout the period.]