HMRC internal manual

Company Taxation Manual

CTSA: Revenue determination: Power to make

You should check the other guidance available on GOV.UK from HMRC as Brexit updates to those pages are being prioritised before manuals.


A company may fail to deliver a company tax return in response to a notice to deliver under FA98/SCH18/PARA3. When this happens you can determine the amount of tax payable by the company to the best of your information and belief.

A Revenue determination:

  • can include an estimated amount of profits or estimated amounts of particular types of profit,
  • may contain relief for losses, deficiencies and other amounts brought forward from a previous accounting period,
  • indicates the rate, or rates, at which you estimate that tax is due.

The power to make a determination under Paragraph 36 includes the power to determine:

  • any of the amounts mentioned in FA98/SCH18/PARA8 (CTM93110),


  • any amount that forms part of the calculation of any of those amounts.