Who may submit a revised group allowance allocation statement under section 269DH?

Under section 269DH of the Corporation Tax Act 2010, the right to submit a revised group allowance allocation statement belongs to whichever company is currently the nominated company for the banking group. This applies even if a different company originally submitted the initial statement, provided a valid group allowance nomination is in place.

What is the time limit for submitting a revised group allowance allocation statement to HMRC?

A revised statement must generally be submitted within 36 months of the end of the nominated company's accounting period. However, the deadline is extended to 30 days after the completion of an HMRC enquiry, the issue of an amendment notice, or the final determination of an appeal. An HMRC officer may also permit late submission.

Does a backdated group allowance nomination invalidate a previously submitted revised statement?

No. Under section 269DH, if a new group allowance nomination takes effect from a date earlier than it was actually made, it does not invalidate any revised group allowance allocation statement that was submitted before the new nomination was made. This protects groups from having earlier filings undermined by subsequent administrative changes.

Are extended time limits available for all HMRC enquiries under section 269DH?

No. The extended time limits do not apply where HMRC opens a limited-scope enquiry triggered by an amendment to a relevant company tax return, where the enquiry scope is restricted to matters arising from that amendment and the amendment relates solely to the allocation of group surcharge allowance for the nominated company's accounting period.

Corporation Tax Act 2010 section 269DH

Group allowance allocation statement: submission of revised statement

Section 269DH sets out the rules governing when and how a revised group allowance allocation statement may be submitted to HMRC, including the time limits for doing so.

Where a group allowance allocation statement has already been submitted, the current nominated company for the group may submit a revised statement to HMRC in respect of the same accounting period.
A revised statement must generally be submitted within 36 months of the end of the relevant accounting period, though this deadline is extended where HMRC enquiries, amendments or appeals are ongoing — in each case to 30 days after the relevant event concludes.
An HMRC officer may permit a revised statement to be submitted after the normal deadlines have passed.
Any revised statement must meet the same formal requirements as the original statement, as set out in section 269DI, and a backdated group allowance nomination does not invalidate a revised statement that was submitted before the new nomination was made.

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