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HMRC internal manual

Company Taxation Manual

Corporation tax self-assessment (CTSA): Claims and elections: Reduction in overall liability

FA98/SCH18/PARA64 makes sure that claims made, given, revoked or varied under FA98/SCH18/PARA62:

  • cannot reduce the tax liability (to CT, IT and CGT) of:

    • the company, and
    • any other persons affected,

    by a greater amount than the additional liability to tax arising from the amendment or assessment.

    When this provision limits:

    • the reduction in a person’s liability for more than one period, or
    • the reduction in liability to tax of more than one person,

    the limited amount is to be apportioned between the periods or persons concerned.

    You will make this apportionment in the first instance and issue a written notice to the person or persons concerned - Paragraph 64 (3).

    If the person(s) concerned wish to apportion the limited amount differently, they must give you written notice within 30 days of the date of issue of your notice. If more than one person is concerned, the notice must be given jointly - Paragraph 64 (4).