Commentary

D6.618 Capital treatment—reporting obligations

Corporate tax
Corporate tax | Commentary

D6.618 Capital treatment—reporting obligations

Corporate tax | Commentary

D6.618 Capital treatment—reporting obligations

A company making a payment which it considers to be within the capital treatment rules has a reporting obligation. Within 60 days of the payment it must make a return to HMRC giving particulars of the payment and of the circumstances regarded as justifying the application of that section to it1. The return must be made even if HMRC have confirmed, following a clearance application (D6.605), that the rules will apply to the payment2.

Under the HMRC information and inspection powers (A6.316), if HMRC have reason to believe that a payment forms part of a scheme or

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