Section 218: Commercial reasons for change of accounting date
888.This section deals with three aspects of the “commercial reason” condition in section 217(6)(a):
the automatic assumption of commerciality;
timely notice by the Inland Revenue to the contrary; and
appeals to the Commissioners if the Inland Revenue’s view is disputed.
It is based on section 62A(5), (6), (7), (8), and (9) of ICTA.
889.Subsection (1) makes the effect of section 62A(5)(b) of ICTA clear: that a change is treated as having been made for a commercial reason in the absence of a timely challenge by the Inland Revenue.
890.Subsection (6) prevents a wish to obtain a tax advantage from being a commercial reason for the change of accounting date rules.
