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HMRC internal manual

COTAX Manual

Penalties: late delivery of returns: reasonable excuse

This subject is presented as follows.

Reasonable excuse
Request for further time

Reasonable excuse

The statutory filing date (Word 42KB) for a return is at least 12 months after the end of the AP. In most cases COTAX issues a reminder about one month before that date if a return has not been logged.

The normal amount of time allowed should therefore be adequate to keep successful claims for reasonable excuse to a minimum.

However, there will be a few occasions each year when companies make every endeavour to meet their filing obligations, but fail by reason of unforeseen misfortune.

It is not the intention to penalise such companies, provided that there was a reasonable excuse for the failure and it was remedied as soon as could reasonably be expected after the excuse had run out.

There is no statutory definition of reasonable excuse.

For further information about reasonable excuse see the Enquiry Manual at EM5152 and the CT Manual at CTM94140 and CTM94150.

Request for further time

A company may request further time in which to deliver its return when it does not expect to meet its filing date. It may make the request at any time before delivery of the return.

If you agree to the request the company will not be liable to a penalty if it delivers its return within the further time allowed. For more information about further time, see the CT Manual at CTM94130.

In considering a request for further time you should apply the reasonable excuse provisions described at CTM94140 and CTM94150.

If you accept that a company has a reasonable excuse for the anticipated delay, you should allow further time up to the date when you expect the reasonable excuse to cease.

You record an agreement to further time on COTAX by using function RDAC (Record Filing Date Adjustment) to enter a deferred filing date.


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