The Controlled Foreign Companies (Reversal of State Aid Recovery) Regulations 2024
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2 Reversal of state aid recovery
(1) An officer of HMRC must— (a) give a notice (a “reversal notice”) to any company affected by Schedule 7ZA (“Schedule 7ZA”) of the Taxation (International and Other Provisions) Act 2010, and (b) cancel any interest charging notice given to the company. (2) A reversal notice must— (a) cancel any charging notice and consequential amendment notice given to the company, and (b) make any relevant adjustment, in relation to the company, relating to any accounting period, which the officer considers appropriate for the purposes of securing, so far as reasonably practicable, that the company is put into the position it would have been in if— (i) the Commission Decision had not been made, and (ii) Schedule 7ZA had not had effect. (3) A reversal notice must be given and any interest charging notice cancelled as soon as reasonably practicable after these Regulations come into force.
2 Reversal of state aid recovery
(1) An officer of HMRC must— (a) give a notice (a “reversal notice”) to any company affected by Schedule 7ZA (“Schedule 7ZA”) of the Taxation (International and Other Provisions) Act 2010, and (b) cancel any interest charging notice given to the company. (2) A reversal notice must— (a) cancel any charging notice and consequential amendment notice given to the company, and (b) make any relevant adjustment, in relation to the company, relating to any accounting period, which the officer considers appropriate for the purposes of securing, so far as reasonably practicable, that the company is put into the position it would have been in if— (i) the Commission Decision had not been made, and (ii) Schedule 7ZA had not had effect. (3) A reversal notice must be given and any interest charging notice cancelled as soon as reasonably practicable after these Regulations come into force.
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