Taxes Consolidation Act 1997 section 638

Apportionment of amounts

Section 638 provides a mechanism for resolving disputes over apportionments that affect the tax liabilities of two or more companies.

• Where an apportionment is material to the tax liability of two or more companies and the company and the inspector cannot agree, the inspector makes a determination and notifies each affected company in writing.
• A company aggrieved by the inspector's determination may appeal to the Appeal Commissioners within 30 days of the date of the notice.
• The appeal is made in accordance with section 949I, and the Appeal Commissioners determine a just and reasonable apportionment.
• All companies affected by the apportionment are entitled to appear before and be heard by the Appeal Commissioners.