HMRC has updated its guidance Pay corporation tax if you’re a large company to note that, in exceptional circumstances, a repayment claim for instalment payments can be made where the company’s revised calculation of liability includes anticipated losses from a current accounting period that has not yet ended. In such cases, where the business has sustained significant losses, HMRC will require supporting evidence to verify the losses and support the claim for repayment. HMRC has also updated its Company Taxation Manual at CTM92650 accordingly.
Commenting on the announcement, Melissa Geiger, head of international tax and tax policy for KPMG UK, noted that ‘the change means that HMRC could consider repayment claims as long as there are “exceptional circumstances”. Our understanding is that exceptional circumstances means that a company must have evidence to suggest the trade losses in the current accounting period are likely to be so large that they will comfortably exceed any other relevant income in the current accounting period ... Businesses should be aware, however, that this does not mean that all claims will be accepted. They will be reviewed carefully by HMRC on a case by case basis and HMRC have said companies will need to provide ‘full evidence’ to support any claims.’
HMRC has updated its guidance Pay corporation tax if you’re a large company to note that, in exceptional circumstances, a repayment claim for instalment payments can be made where the company’s revised calculation of liability includes anticipated losses from a current accounting period that has not yet ended. In such cases, where the business has sustained significant losses, HMRC will require supporting evidence to verify the losses and support the claim for repayment. HMRC has also updated its Company Taxation Manual at CTM92650 accordingly.
Commenting on the announcement, Melissa Geiger, head of international tax and tax policy for KPMG UK, noted that ‘the change means that HMRC could consider repayment claims as long as there are “exceptional circumstances”. Our understanding is that exceptional circumstances means that a company must have evidence to suggest the trade losses in the current accounting period are likely to be so large that they will comfortably exceed any other relevant income in the current accounting period ... Businesses should be aware, however, that this does not mean that all claims will be accepted. They will be reviewed carefully by HMRC on a case by case basis and HMRC have said companies will need to provide ‘full evidence’ to support any claims.’
