The Controlled Foreign Companies (Reversal of State Aid Recovery) Regulations 2024
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Change 1
3 Consequential adjustments
(1) A company affected by a reversal notice may make a relevant adjustment in relation to an amount— (a) arising in consequence of a relevant adjustment made in a reversal notice, and (b) relating to any accounting period ending on or after 1st January 2019. (2) A relevant adjustment under this regulation must be made within a period of 12 months beginning immediately after the end of the accounting period of the company in which the reversal notice is given (whether given to that company or another company). (3) If a relevant adjustment relates to a claim, election, application or notice previously made or given, the claim, election, application or notice must be revoked or varied— (a) in the same manner as it was made or given, and (b) by or with the consent of the same person or persons who made, gave or consented to it. (4) If the effect of a relevant adjustment under this regulation would be to alter the liability to tax of another person, the adjustment may not be made except with the consent in writing of that other person. (5) Where a relevant adjustment under this regulation is made so as to increase the liability to tax of another person, paragraph 61 of Schedule 18 to FA 1998 does not apply in relation to any amendment or assessment made because of that increased liability.
3 Consequential adjustments
(1) A company affected by a reversal notice may make a relevant adjustment in relation to an amount— (a) arising in consequence of a relevant adjustment made in a reversal notice, and (b) relating to any accounting period ending on or after 1st January 2019. (2) A relevant adjustment under this regulation must be made within a period of 12 months beginning immediately after the end of the accounting period of the company in which the reversal notice is given (whether given to that company or another company). (3) If a relevant adjustment relates to a claim, election, application or notice previously made or given, the claim, election, application or notice must be revoked or varied— (a) in the same manner as it was made or given, and (b) by or with the consent of the same person or persons who made, gave or consented to it. (4) If the effect of a relevant adjustment under this regulation would be to alter the liability to tax of another person, the adjustment may not be made except with the consent in writing of that other person. (5) Where a relevant adjustment under this regulation is made so as to increase the liability to tax of another person, paragraph 61 of Schedule 18 to FA 1998 does not apply in relation to any amendment or assessment made because of that increased liability.
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