Taxation (International and Other Provisions) Act 2010 section 371JG

Amendment of company tax returns

Section 371JG extends the time limit for amending company tax returns where those returns relate to a CFC's exempt period, because the correct tax position can only be determined after the exempt period has ended.

• This section applies where a CFC's exempt period falls wholly or partly within a company's corporation tax accounting period.
• The company may amend its tax return, in so far as the amendment relates to the exempt period exemption or profit adjustments under section 371JE, up to 12 months after the relevant filing date.
• The relevant filing date is the filing date for the company's corporation tax return for the accounting period in which the CFC's first accounting period beginning after the end of the exempt period ends.
• This extension is necessary because whether any chargeable profits arise during the exempt period can only be confirmed once the CFC's position for the subsequent period has been established.