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HMRC internal manual

Company Taxation Manual

Corporation Tax self-assessment (CTSA): the payment obligation: collectible amounts

CTSA accounting periods

Under CTSA the tax charged in a Revenue determination is collectible as if it were charged in a SA (FA98/SCH18/PARA39) unless and until the determination is superseded by a SA, see CTM95370.

If the Revenue determination is the subject of recovery proceedings at that time, they may be continued as if they were proceedings for the amount charged by the SA but unpaid.

CTPF accounting periods

Under CTPF the CT liability shown in a return is collectible as if it were charged in an assessment, and the Collector can take formal recovery proceedings for it.

If an amended return is made (CTM93310) our enforcement power applies to the liability shown in the amended return.

Note that any overpayment shown by an amended return, like an overpayment shown by an original return, is not automatically repayable.

You must first:

  • examine the return or amended return,


  • agree the figures,

or, (as the case may be)

  • give a decision on the claim.

This is in contrast to the position under CTSA, when the return contains a SA and companies normally give effect to claims themselves, either in or by amending their return and SA.