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HMRC internal manual

Company Taxation Manual

Corporation Tax self-assessment (CTSA): Assessments: Appeals

FA98/SCH18/PARA92 to 94

Any notice of appeal under Schedule 18 must include the grounds of the appeal.

A company can appeal against:

  • a jeopardy amendment made to a self assessment during the course of an enquiry - FA98/SCH18/PARA30, (see EM1950 onwards for information about jeopardy amendments)
  • a revenue amendment to a company tax return at the conclusion of an enquiry - FA98/SCH18/PARA34 (2), (see EM3833 onwards for information about revenue amendments)
  • a consequential amendment to a company tax return of another accounting period at the conclusion of an enquiry – FA98/SCH18/PARA34 (2A) (see EM3878 onwards for information about consequential amendments)
  • an assessment to tax other than a self assessment - FA98/SCH18/PARA41 (1)
  • a discovery determination of losses, and so on - FA98/SCH18/PARA41 (2), (see CTM95500 onwards).

Note: There is no right of appeal against a determination of tax payable in the absence of a return made under FA98/SCH18/PARA36 or 37.

Any appeal hearing would be before the First Tier Tribunal subject to any provision under the Tribunal Procedure Rules which allows or requires the appeal to go before the Upper Tribunal.

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