Amendments of Part 4 of FA 2014
3(1)Section 220 (content of notice given while a tax enquiry is in progress) is amended as follows.
(2)In subsection (2)—
(a)in paragraph (b), after “the payment” insert “(if any)”, and
(b)omit the “and” at the end of that paragraph, and after paragraph (c) insert “, and
(d)if the denied advantage consists of or includes an asserted surrenderable amount, specify that amount and any action which is required to be taken in respect of it under section 225A.”
(3)After subsection (4) insert—
“(4A)Asserted surrenderable amount” means so much of a surrenderable loss as a designated HMRC officer determines, to the best of that officer’s information and belief, to be an amount—
(a)which would not be a surrenderable loss of P if the position were as stated in paragraphs (a), (b) or (c) of subsection (4), and
(b)which is not the subject of a claim by P for relief from corporation tax reflected in the understated tax amount (and hence in the payment required to be made under section 223).
(4B)“Surrenderable loss” means a loss or other amount within section 99(1) of CTA 2010 (or part of such a loss or other amount).”
(4)In subsection (6), for “the payment specified under subsection (2)(b)” substitute “any payment specified under subsection (2)(b) or amount specified under subsection (2)(d)”.