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HMRC internal manual

COTAX Manual

Penalties: late delivery of returns: deferred filing dates

A company may claim that, although it has delivered a return later than the filing date (Word 42KB), late delivery should not be regarded as a failure to comply with legislation.

The claim must be that either of the following apply.

  • The company is entitled to deliver its statutory accounts for the return period by a date later than the filing date. See COM100010 for more information.
  • The company has a reasonable excuse for failing to deliver the return and then makes the delivery without unreasonable delay after the excuse has ceased.

See COM100100 for more information.

When you accept under one of these conditions that delivery of the return by a date later than the filing date should not be regarded as a failure, record the later date on COTAX using function RDAC (Record Filing Date Adjustment).

COTAX refers to this date as a ‘deferred filing date’. This is an administrative term only, because in law, the filing date has not been deferred.

When you record a deferred filing date, COTAX automatically:

  • determines if a penalty is due and recalculates it if appropriate
  • issues amended determinations where penalty liability is changed as a result of the deferred filing date.

You should not determine an appeal against a penalty determination when the return is still outstanding even when the return is not yet due by reference to the deferred filing date. If the company does not deliver the return by the deferred filing date, it may still be liable to a penalty for the return period.


  • COM100012 for a list of functions to use in particular situations
  • COM100013 for legislation applying to this subject.