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HMRC internal manual

Company Taxation Manual

Corporation Tax self assessment (CTSA): group relief - general: time limit

FA98/SCH18/PARA74 lays down the time limit in which companies can make or withdraw group relief claims.

The limit is:

  • at any time up to the first anniversary of the filing date for the accounting period of the claim.

This is normally (and will not be earlier than) two years after the end of a claimant company’s accounting period. However, it will be later than that:

  • if the accounting period ends during a period of account either:
    • because an event occurs to cause an accounting period to end during a twelve month period of account, or
    • because the period of account lasts longer than twelve months.
  • if the notice to deliver is issued so late that the filing date is determined by the date of receipt of the notice, rather than the end of the accounting period or period of account, see CTM93030 onwards for guidance on filing dates.

Example 1

The specified period in the notice to file issued under FA98/SCH18/PARA3 is the first twelve months covered by the accounts and those first twelve months are an accounting period.

Period of account (for a claim or withdrawal for any accounting period that ended during, or at the end of the period of account) Accounting period ended Filing date Time limit
1.1.09 - 31.12.10 (24 months) 31.12.09 30.6.11 30.6.12
1.1.09 - 31.7.10 (19 months) 31.12.09 30.6.11 30.6.12
1.7.09 - 31.1.11 (19 months) 30.6.10 31.12.11 31.12.12

Example 2

The accounting period ends at the end of a twelve-month period of account. The specified period in the notice to deliver issued under FA98/SCH18/PARA3 is the first twelve months covered by the accounts and those first twelve months are an accounting period.

Date of service of notice to deliver Accounting period ended Filing date Time limit
28.1.10 31.12.09 31.12.10 31.12.11
20.10.10 31.12.09 20.1.11 20.1.12
10.6.11 31.12.09 10.9.11 10.9.12