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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Companies: Rights and Obligations: Discovery Determinations - Examples

A company tax return for the period ended 31/12/2006 shows no liability, and a trade loss of £60,000 carried forward to future years. You make a discovery which leads to the conclusion that the loss available to carry forward should be reduced, but not to the extent of creating liability for the period ended 31/12/2006. As the company’s tax liability for future accounting periods may be affected, you can make a discovery determination of losses for that accounting period of between £59,999 and £0.

If the loss had been surrendered as group relief, the tax liability of another company will be affected. You can make a discovery determination of between £59,999 and £0 and follow the procedure in CTM97070.