EM8313 - Companies: Quarterly Instalment Payments: Interaction with CTSA Enquiries

Items you request to check the company’s compliance with its obligation to make instalment payments may also be required in connection with an enquiry into the CTSA return. If you have opened both an enquiry into the CTSA return and written to the company in connection with its obligation to make instalment payments, you will be able to make use of either or both formal information powers, as appropriate. The fact that you have obtained information for one purpose will not prevent you using it for the other as well.

You are able to enquire into the Quarterly Instalment Payment position without opening an enquiry into the Company Tax Return. If you clearly state that the purpose of your request is to check the QIP position and you ask only for information under Regulations 10,11 and 12 you should be able to demonstrate that you have not opened an enquiry into the return.

If a company or its professional adviser claims that a request for information about Quarterly Instalment Payments constitutes the opening of an enquiry into the Company Tax Return you should

• explain that the purpose of your request is to check the Quarterly Instalment Payment position
• refer to the specific authority in Regulations 10,11 and 12 for such requests
• point out that you have not issued a notice of intention to enquire into the return, EM1550+.

If, after these explanations, the company maintains that you have opened an enquiry into the return make a report to contact link.