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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
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Opening the Enquiry: CTSA Time Limits - The group anniversary target

EM1510 explains that there are different time limits for opening an enquiry into company returns for accounting periods ending after 31 March 2008.

  • For a company that is a member of a group that is not small, see EM1512 and EM1513, we may open an enquiry within 12 months of the statutory filing date.
  • For other companies, if the return is received before the statutory filing date, we may open an enquiry within 12 months of the date of receipt of the return.

Companies in a group that is not small

Where a company is a member of a group that is not small, it is required to tick the ‘company part of a group that is not small’ box on page 1 of the CT600 return form.

In such circumstances, although you have until 12 months from the statutory filing date to open an enquiry, where it is practical to do so you should aim to open all enquiries in to a group’s return within 12 months of the delivery of the last individual company tax return from any member of the group. We call this ‘the group anniversary target’.

Example

A Ltd, B Ltd and C Ltd are the members of a group. They all have the year 31 December 2010 as an accounting period. Their joint turnover for 2008 is £23 million. The group’s balance sheet value is £10 million. So irrespective of the number of employees, the group is not a ‘small group’ in Companies Act terms.

The companies deliver their company tax returns on the following dates:

A Ltd 23 September 2011
   
B Ltd 14 August 2011
C Ltd 9 October 2011

 

The statutory filing date for each company is 31 December 2011. We have until 31 December 2012 to give notice of enquiry into any of these returns. But if it is practical to do so, we should aim to meet the group anniversary target and open any enquiries into any of these company tax returns no later than 9 October 2012.

It will not always be practical for you to undertake to meet the group anniversary target. Where it is not, you should continue to open enquiries as necessary, within the statutory deadline.

For the approach to these operational guidelines in different business units, see EM1515.