F1PART 9AControlled foreign companies
Chapter 21Management
371UCJust and reasonable apportionments
1
This section applies if—
a
an apportionment of a CFC's chargeable profits and creditable tax is to be made in accordance with section 371QC(2), and
b
a company tax return is made or amended using for the apportionment a particular basis adopted by the company making the return.
2
An officer of Revenue and Customs may determine that another basis is to be used for the apportionment; and matters are then to proceed as if that were the only basis allowed by the Taxes Acts.
3
The officer's determination may be questioned on an appeal against an amendment of the company's tax return made under paragraph 30 or 34 of Schedule 18 to FA 1998.
4
But it may be questioned only on the ground that the basis of apportionment determined by the officer is not just and reasonable.
Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)