DST63900 - Determination Superseded by Self-Assessment
If, after an HMRC determination has been made, a DST return is delivered for the accounting period, the self-assessment included in the return supersedes the determination provided the return is delivered no later than:
- 3 years after the day on which the power to make the determination first became exercisable, or
- twelve months after the date of the Revenue Determination.
The following example with different scenarios demonstrates how and when a Revenue Determination is superseded by a Self-Assessment return:
Example
- Group A makes up its accounts to 31 December annually.
- The filing date for the return is 31 December 2022.
- 1 January 2023 is the day which the power to make the determination first became exercisable
- HMRC have reasonable grounds for believing the responsible member is under a duty to deliver a DST return for the accounting period.
Scenario 1
- HMRC make a Revenue Determination for that period on 10 July 2023
- The responsible member delivers a return in February 2024
- The Self-Assessment supersedes the Revenue Determination;
- as it is within 12 months after the date of the Revenue Determination
- it is also within 3 years after the day on which the power to make the determination first became exercisable
Scenario 2
- HMRC make a Revenue Determination for that period on 10 July 2023
- The responsible member delivers a return in October 2024
- The Self-Assessment supersedes the Revenue Determination;
- as it is within 3 years after the day on which the power to make the determination first became exercisable
- even though it is more than 12 months after the date of the Revenue Determination
Scenario 3
- HMRC make a Revenue Determination for that period on 10 March 2025
- The responsible member delivers a return in February 2026
- The Self-Assessment supersedes the Revenue Determination;
- as it is within 12 months after the date of the Revenue Determination
- even though it is more than 3 years after the day on which the power to make the determination first became exercisable
Scenario 4
- HMRC make a Revenue Determination for that period on 10 March 2025
- However, the responsible member delivers a return in April 2026
- The Self-Assessment does not supersede the Revenue Determination;
- as it is more than 12 months after the date of the Revenue Determination
- it is also more than 3 years after the day on which the power to make the determination first became exercisable.