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HMRC internal manual

Shares and Assets Valuation Manual

HM Revenue & Customs
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Self Assessment: Corporation Tax Self Assessment (CTSA) - Consequences for SAV Practice

Much of the basic framework for CTSA enquiries (including into valuations) is similar to the framework for Income Tax Self Assessment (ITSA).

You need to be sure that an enquiry has been opened before seeking information from the company or questioning a valuation in a CTSA case. For the purposes of the enquiry window, you should assume that the return was filed on time unless the Inspector advises you otherwise. As with ITSA, you should notify Large Business of the need to open an enquiry.

If you reach an agreement on value and notify it to the Inspector in the normal way, the Inspector will close the enquiry either then or when any other outstanding issues are settled or need to be brought to a head.

No unagreed valuation should be included in a notice of closure issued by the Inspector until the Litigation and Technical Advice Team (LTAT) has been consulted. (See Chapter 117 of this manual SVM117000.)

You need to be aware of the separate information powers for CTSA (set out in the Enquiry Manual EM2200). If you face difficulty in obtaining information, you should ask the appropriate Inspector to use the relevant information powers at an early stage. If you are in any doubt as to which information power is appropriate, you will need to liaise closely with the relevant Customer Relationship Manager (CRM).

  Additional Guidance: SVM150000