Taxation (International and Other Provisions) Act 2010 section 50

Interest restriction returns to be submitted to an officer of Revenue and Customs

Section 50 sets out the requirements for submitting interest restriction returns following a closure notice issued after an HMRC enquiry into an existing return.

  • When HMRC issues a closure notice after an enquiry and the company must submit one or more revised interest restriction returns, these must be sent to an officer of HMRC, reflect the conclusions in the closure notice, and include any consequential adjustments the company considers appropriate.
  • A revised return submitted in response to a closure notice has no legal effect unless HMRC receives it within three months of the date the closure notice was given to the company.
  • The revised return must clearly identify the differences between itself and the original return that was under enquiry, and it supersedes that original return once validly submitted.
  • If no return is submitted within the three-month deadline, separate provisions under paragraph 58 apply to deal with the consequences of non-compliance.

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