Commentary

D1.943 Corporate capital losses anti-avoidance—notices issued by HMRC

Corporate tax
Corporate tax | Commentary

D1.943 Corporate capital losses anti-avoidance—notices issued by HMRC

Corporate tax | Commentary

D1.943 Corporate capital losses anti-avoidance—notices issued by HMRC

The anti-avoidance provisions described in D1.941, D1.942 only come into effect if HMRC issues a notice that they should apply (a 'relevant notice'). There is no requirement for a company to take account of these provisions in preparing its self-assessment returns unless it has received such a notice.

Issue of relevant notice

HMRC may only issue a relevant notice if they consider, on reasonable grounds, that the conditions in one or both of the provisions are satisfied1.

The relevant notice may exceptionally be issued before the company has made its corporation tax return for the accounting period in question2. In that case, if the company makes its return without reference to the notice, it may amend the return within 90 days of the issue of the

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