Taxation (International and Other Provisions) Act 2010 section Sch 7A para 4

Appointment of reporting company by Revenue and Customs

Schedule 7A paragraph 4 allows HMRC to step in and appoint a reporting company for a worldwide group when the group itself has failed to make a valid appointment and the deadline for doing so has passed.

• HMRC can appoint a reporting company when the group has not done so and the window for the group to self-appoint has closed.
• The appointment is made by HMRC issuing a notice to an eligible UK group company that was active during the relevant period of account.
• HMRC must generally act within four years of the end of the relevant period of account, but can act later if a UK group company's tax return for a relevant accounting period can still be amended.
• An eligible company must have been a UK group company at some point during the period and must not have been dormant throughout that period.