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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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Corporation Tax self-assessment (CTSA): Discovery determination: CTPF: Direction - reducing amount

TMA70/S41B

When you discover that a determination of trading losses and other amounts under TMA70/S41A is, or has become, excessive TMA70/S41B lets you issue a “direction” that the amount determined be reduced by a specified amount. As with the determination, a direction has effect when you give notice of it to the company in writing and the normal appeal provisions apply.

Note: The “discovery” principles contained in SP8/91 apply to the making of directions in the same way that they apply to the making of further assessments.

The determination as reduced by the direction is conclusive once the direction becomes final, subject to the qualifications listed at CTM95440.

You can make a further direction in appropriate circumstances. The above provisions apply to the determination as reduced by the earlier direction.

You should make a direction or a further direction using form CT213. (See the On-line Company Tax Manual (COM) subject “Loss Determinations” in the “Assessing” area for guidance on how and when to make directions.)