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HMRC internal manual

Company Taxation Manual

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HM Revenue & Customs
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CTSA: group relief: simplified arrangements: refusal of an application

Regulation 7(4) SI1999/2975

You can refuse an application to enter into a simplified arrangement (CTM97650) at any time within the three months following its receipt. You may only do so if:

  • you have reason to believe that one or more of the companies named in the application is not a member of the group, or is not a consortium company (CTM97680),
  • the group (and any consortium companies) are not dealt with wholly or substantially wholly in the same tax office,
  • the specimen copy of the written statement (CTM97690) is not adequate for the purpose of enabling you to deal with claims for group relief,
  • you have reason to believe that one or more of the companies named in the application has failed to comply with its obligations under the Corporation Tax Acts.

Cases under the last bullet should be referred to CTISA (Technical), see ‘Technical Help’ on the left bar, before any decision is made. Any case where a group objects to the refusal of an application should also be referred to CTISA (Technical).

You should only refuse applications on the grounds in the second bullet if, given the number of companies and tax offices involved, accepting the application would put an unreasonable administrative burden on the Revenue.

  • For partially accepting an application see CTM97750,
  • For terminating a special arrangement or excluding a company from it see CTM97760.