CTM06870 - Corporation Tax: loss buying: extended time limit for assessment
CTA10/S727
CTA10/S727 extends the time limit for HMRC to raise assessments in situations where any of the loss buying rules at CTA10/PART14/CHAPTER2 to CHAPTER6 apply.
From 1 April 2017, there is a change in this provision relating to the circumstances or events from which the time limit is calculated.
The time limit is calculated with reference to the date of any circumstances or events that
- are required for any of the provisions and CHAPTER2 to CHAPTER6 to operate,
- occur after a change in company ownership, and
- with effect from 1 April 2017, occur within five years of the change in ownership - for earlier periods the circumstances or events must occur within three years of the change in ownership.
The extended time limit for assessment is six years from the date of the latest of these circumstances or events.