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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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CTSA: Revenue determination: CTPF: what to determine

You should determine the following amounts:

  • In every case in which a trading loss is suffered:
    • the gross trading loss incurred in an accounting period, before any relief is given for it (computed in the same way as trading profits in that period would have been computed - ICTA88/S393 (7)).
  • If the company is making a group relief surrender:
    • the maximum amounts theoretically available for surrender as group relief under ICTA88/S403 (3), (4) and (7).

These are excess:

  • capital allowances given by discharge or repayment over income of the specified class,
  • management expenses over total profits,
  • charges over total profits.

You should make the determination in the gross figures, whether or not there is a claimant able to use the relief, or any amount has been relieved (or partly relieved) in some other way. The determination must be in writing.

This lets you settle:

  • a surrendering company’s affairs independently of the affairs of the claimant companies,


  • the amount of a trading loss incurred, independently of a claim to relieve it.

TMA70/S41A (6) and TMA70/S41B apply TMA70/S31 to appeals against determinations and directions as it applies to appeals against assessments (AP3372). This is with the exception of TMA70/S31 (3) that is relevant only to certain types of assessment.

Form CT212 is available for making determinations and form CT213 for amending them. Use the CT212 to make your determination if there is any question over the amount determinable. However, there is no objection to you making the determination less formally:

  • in a free-format message on a notice of assessment, entered using Function PASR (prepare assessment based on return) or PAST (prepare full assessment), if you are agreeing to the figure(s) given in the return,
  • in a letter addressed to the company, if there has been correspondence about the determinable amount(s) and you are agreeing to figures proposed by the company.

The determination must state clearly the amount determined and its nature, and that it is determined under TMA70/S41A.