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HMRC internal manual

Company Taxation Manual

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

FA98/SCH18/PARA92 to 94

CTSA accounting periods

CTSA introduces changes to matters that can be the subject of an appeal, such as the new information powers at FA98/SCH18/PARA27. Schedule 18 also contains provisions designed to ensure that the appeals provisions applicable to CTSA, both jurisdictional and procedural, are broadly similar to those that:

  • relate to IT SA, and
  • existed prior to the introduction of SA.

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

Paragraph 93 applies to an appeal against:

  • a jeopardy amendment made to an SA during the course of an enquiry - FA98/SCH18/PARA31, (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 EM1950 onwards for information about Revenue amendments),
  • an assessment to tax other than an SA - 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 of Part V of the TMA70 (such as section 46D) which allows or requires jurisdiction to be with another tribunal.


The appeal provisions of TMA70 are unchanged and continue to apply to assessments made in respect of accounting periods ending on or after 1 October 1993 and before 1 July 1999.