CFM99060 | Interest restriction: administration: penalties: inaccuracy attributable to company other than reporting company

TIOPA10/SCH7A/PARA32

TIOPA10/SCH7A/PARA32 can impose a penalty on a company that causes an inaccuracy to occur in an interest restriction return submitted by a different company, but only in cases where false information is supplied deliberately or information deliberately withheld. Such a penalty is analogous to a penalty under FA07/SCH24/PARA1A, see CH81166 and CH81075.

Such a penalty can apply in addition to a penalty on the reporting company under PARA30, see CFM99020. The level of penalty before any reduction for disclosure or special circumstances CFM99050, CFM99057 is 100% of the notional tax CFM99040.