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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Close Companies: loans to participators and arrangements conferring benefit on participator: assessments

TMA70/S109 applies all the rules in the Corporation Tax Acts to CTA10/Part 10 including the FA13 insertions. This includes, but is not limited to, the rules on assessing, collecting, rights of appeal, administration, penalties and interest with any necessary modifications.

For assessments for accounting periods ended after 30 September 1993 but on or before 30 June 1999, see CTM98250 onwards (CTPF procedures).

If you need to make extended time limit assessments for periods ended up to 30 June 1999 see EM3285. You should keep under review all open cases to which CTA10/S455 or S464A may apply to ensure that any protective assessments that may be needed are made within the time limits.

For accounting periods ended on or after 1 July 1999, see CTM98200 onwards (CTSA rules).

There is guidance on the late payment interest rules at CTM98260 (CTPF) and CTM98240 (CTSA) and repayment interest rules at CTM98265 (CTPF) and CTM98245 (CTSA).