Self Assessment: Corporation Tax Self Assessment (CTSA)
What is CTSA?
CTSA applies to all accounting periods ending on or after 1 July 1999 and detailed guidance can be found in the Company Taxation Manual (CTM90000)
Please see the detailed instructions in the Enquiry Manual EM2200 and EM2470 in respect of third party notices. Chapter 118 of this manual SVM118000 covers the effect on SAV.
An enquiry is treated as finished when HMRC gives written notice of closure to the company, and states its conclusions. Detailed instructions can be found in the Enquiry Manual EM3833.
Code of Practice (COP)
All enquiries into CTSA returns (except those made by Fraud Intelligence Service (FIS), who have their own COP) must be carried out in accordance with the Code of Practice (COP14). This is available on the HMRC Internet site.
Clearly the Code primarily seeks to set out the actions the Inspector may be expected to take. However, as our negotiations of value in a CTSA case will form part of the enquiry opened by the Inspector we need to keep within the COP. If any departure from the Code seems necessary, you should consult the Litigation and Technical Advice Team (LTAT).
Application to close an Enquiry
A company may request a formal review under the new Tribunal rules. If you become aware of such an application that covers any valuation on which you are engaged, you should immediately refer the matter to LTAT who will arrange for the handling of the matter.
|Additional Guidance: SVM150000|