CTM95340 - CTSA: Revenue Determination: Review

You should normally review cases, for a Revenue determination under FA98/SCH18/PARA36, 18 months after what you believe to be the end of the company바카라 사이트™s accounting period. If you believe that the filing date is later than that, you must wait until after the filing date before making a Revenue determination.

You can make a Revenue determination before the 18 months point if you consider that:

  • there would be the risk of a loss of tax if you did not take immediate action,

or

  • the failure to deliver a return is preventing a proper review of other companies in a group.

Companies who are members of a group payment arrangement will have made known to HMRC their accounting period end date. You will thus have sufficient information to ascertain the filing date and make a Revenue determination of tax.

Examples

  • Example 1 shows a straightforward continuing case.
  • Example 2 shows a newly incorporated case.
  • Example 3 shows a newly incorporated case that advises its accounting period and then changes it.

Example 1

  • Company A, a company with an established tax history, makes up its accounts to 31 December annually.
  • A notice to deliver, specifying the period 1 January 2018 to 31 December 2018 is issued on 21 January 2019.
  • The filing date for the return to be 31 December 2019.
  • In the absence of special circumstances, you will review Company A to make a determination under Paragraph 36 after June 2020, if the company has not delivered a return by then.

Example 2

  • Company B is incorporated on 15 January 2018. It gives no information about its activities or intended accounting date.
  • You assume that the first accounting period of Company B is from 15 January 2018 to 14 January 2019.
  • A notice to deliver, specifying that period is issued on 18 January 2019 and the filing date is 14 January 2020.
  • In the absence of further information or special circumstances you will review Company B for determination after 14 July 2020.

Example 3

  • Company C is incorporated on 1 September 2018. In the absence of any further information, you assume that its first accounting period is from 1 September 2018 to 31 August 2019.
  • A notice to deliver, specifying that period, is issued on 16 September 2019 and the filing date is 31 August 2020.
  • In October 2019, in response to the notice, Company C tells you that it did not start to trade until 28 September 2018 and that it will draw up its first accounts to 31 December 2019.

Based on this information:

  • The first return that Company C should deliver is for the dormant period 1 September 2018 to 27 September 2018 (FA98/SCH18/PARA5 (3)).
  • The filing date for that return is 3 months after the date of service of the notice to deliver, 19 December 2019(FA98/SCH18/PARA14 (1)(d)). Three working days are assumed to be necessary for delivery of the notice in the ordinary course of the post.
  • No other return is due in response to the notice to deliver that was issued in September 2019.
  • The first accounting period of the company is the period 28 September 2018 to 27 September 2019 and the second is from 28 September 2019 to 31 December 2019.
  • The filing date for the returns for those periods is 31 December 2020, provided that an appropriate notice to deliver is served before 1 October 2020 (Paragraph 14 (1)(a) and (b)).
  • In practice, you will not insist on a formal return for the dormant period and you will review Company C for a Revenue determination under FA98/SCH18/PARA36 after 30 June 2021.