Finance Act 1998

25 (1) An enquiry into a company tax return extends to anything contained in the return, or required to be contained in the return, including— U.K.

(a) any claim or election included in the return,

(b) any amount that affects or may affect—

(i) the tax payable by that company for another accounting period, or

(ii) the tax liability of another company for any accounting period,

[F1 and also extends to consideration of whether to give the company [F2 a notice within sub-paragraph (3)]. But this is subject to the following limitation.]

(2) If the notice of enquiry is given—

(a) as a result of an amendment by the company of its return, and

(b) at a time when it is no longer possible to give notice of enquiry under paragraph 24(2) or (3),

the enquiry into the return is limited to matters to which the amendment relates or which are affected by the amendment.

[F3 (3) A notice is within this sub-paragraph if it is—

(a) a notice under section 184G or 184H of the Taxation of Chargeable Gains Act 1992 (avoidance involving capital losses),

(b) a notice under section 81(2) of TIOPA 2010 (schemes and arrangements designed to increase relief),

(c) a transfer pricing notice under section 168(1) of TIOPA 2010 (provision not at arm's length: medium-sized enterprise), or

(d) a notice under section 232 or 249 of TIOPA 2010 (avoidance involving tax arbitrage).]

Textual Amendments

F1 Words in Sch. 18 para. 25(1) substituted (with effect in accordance with s. 37 of the amending Act) by Finance Act 2004 (c. 12), Sch. 5 para. 10

F2 Words in Sch. 18 para. 25(1) substituted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 321(2) (with Sch. 9 paras. 1-9, 22)

F3 Sch. 18 para. 25(3) inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 8 para. 321(3) (with Sch. 9 paras. 1-9, 22)

Modifications etc. (not altering text)

C1 Sch. 18 para. 25 applied (with modifications) (with effect in accordance with reg. 1(2) of the amending S.I.) by The Lloyds Underwriters (Tax) Regulations 2005 (S.I. 2005/3338), regs. 1(1), 5