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HMRC internal manual

COTAX Manual

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Claims / reliefs: CTSA claims frameworks: time limit for making claims

The general time limit for making a claim for relief is four years from the end of the AP to which the claim relates. This general time limit may be overridden by any specific time limit applying for a particular claim. The AP to which a claim relates is the period in which the event or occasion giving rise to the claim occurs.

Example

J Ltd sustains a trading loss for the AP ended 31 December 2011 and claims under Section 393A(1)(b) ICTA 1988 to set this loss off against its profits for its AP ended 31 December 2010.

The claim relates to the AP ended 31 December 2011 in which the loss occurred.

Section 393A(10) contains a specific two-year time limit, which overrides the general time limit in Paragraph 55.

So the loss relief claim must be made by 31 December 2013.

For legislation applying to this subject, see COM52012.