Corporation Tax Act 2010 section 269ZZA

Excessive specifications of deductions allowance

Section 269ZZA requires a company to correct its tax return if it has claimed too much deductions allowance, and gives HMRC the power to assess additional tax where overclaimed relief has arisen.

• Where a company's tax return overstates any category of deductions allowance (including trading profits, chargeable gains, non-trading income profits, contractor's ring fence profits, or BLAGAB deductions allowance), the company must amend its return to correct the excessive amount as far as it is able to do so.
• If an HMRC officer considers that too much tax relief has been given because the specified deductions allowance was excessive, the officer may make an assessment to recover the tax that should have been charged.
• Where the excessive amount arose because of a change to the group deductions allowance allocated to the company, and the company has failed or is unable to amend its return, HMRC may still make an assessment provided it is made within 12 months of the date the group allocation was altered.
• The power to make an assessment under this section does not limit HMRC's separate power to make a discovery assessment under Schedule 18 to the Finance Act 1998.