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HMRC internal manual

COTAX Manual

HM Revenue & Customs
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CT Pay and File: assessments: loss determinations (S41 TMA 70): directions

S41B TMA 1970 allows a caseworker to issue a direction for a CT Pay and File AP to reduce a determination by a specified amount when either of the following are found to be excessive:

  • trading losses
  • amounts available for surrender as group relief.

See COM152010 for more information.

A direction takes effect when the caseworker gives notice of it to the company.

The normal appeal provisions apply and a determination, as reduced by a direction, is conclusive once it becomes final, subject to certain qualifications. See COM152010 for details of those.

You must issue a letter to amend a loss determination, for example on the settlement of an appeal, or to make a direction.

If you have not already given the reason for the direction to the company, give an explanation in the letter.

See COM152013 for legislation applying to this subject.