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HMRC internal manual

Company Taxation Manual

Corporation Tax self-assessment (CTSA): Discovery determination: Information available

FA98/SCH18/PARA44 (2)

The company has made information available (Paragraph 44(2)) if it is:

  1.  contained in:
  • a return made by it for the period (or either of the two preceding accounting periods) or
  • documents accompanying such a return.
  1.  contained in:
  • a claim made by it for the period (including a CFC application under section 751A of ICTA88), or in accounts, statements or
  • accounts, statements ordocuments accompanying a claim.
  1.  contained in any documents, accounts or other information produced or provided for the purposes of an enquiry into any such return or claim.

  2.  information whose existence and relevance to the loss of tax or statement of an incorrect amount:

  • could reasonably be expected to be inferred from any of the above or
  • was notified in writing to the HMRC.

A change of opinion on information previously made available in a relevant return, and whose relevance was clear, is not grounds for making a discovery determination.