CTM06870 - Corporation Tax: loss buying: extended time limit for assessment

CTA10/S727

S727 extends the time limit for HMRC to raise assessments in situations where any of the loss buying rules at CTA10/PART14/CH2-6 apply.

As of 1 April 2017, there has been 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 Chapters 2 to 6 to operate,
• occur after a change in company ownership, and
• as of 1 April 2017, occur within five years of the change in ownership. For prior periods, however, the circumstances or events must occur within three years of the change in ownership.

The extended time limit is six years from the date of the latest of these circumstances or events.