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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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CTSA: Revenue determination: enforcement power

A Revenue determination has the same effect for enforcement purposes as an SA - FA98/SCH18/PARA39. ‘Enforcement purposes’ means the purposes of:

  • the following parts of TMA70:
    • Part VA (payment),
    • Part VI (collection and recovery),
    • Part IX (interest on overdue tax), and
    • Part XI (miscellaneous and supplementary provisions),
  • the provisions of Schedule 18 imposing tax-related penalties,
  • the provisions of the Corporation Taxes Acts enabling unpaid tax assessed on a company to be assessed on other persons.

The period for which you make the determination is treated for these purposes as an accounting period of the company, even if in the case of a determination under:

  • FA98/SCH18/PARA36 - you have insufficient information to determine what the accounting period is.
  • FA98/SCH18/PARA37 - you have insufficient information to determine whether the outstanding period is an accounting period