COM23175 - Assessing: CTSA assessments: revenue determinations: Stranded Revenue Determination Example

Stranded Revenue Determination Example 

A company is incorporated on 01/10/2018. It tells HMRC nothing about its accounting intentions. COTAX creates the following Accounting Periods (APs) based on the date of incorporation:

  • 01/10/2018 to 30/09/2019
  • 01/10/2019 to 30/09/2020

It issues a notice to deliver about 3 weeks after the end of each AP.
In the absence of returns or any further information, the Technical Caseworker makes Revenue Determinations for both APs.

The company submits returns showing:

  • 01/10/2018 to 30/06/2019 Dormant
  • 01/07/2019 to 30/06/2020 Live (trading)

COTAX automatically links the superseding live AP ended 30/06/2020 to the Revenue Determination ended 30/09/2020, as both end in the period 01/10/2019 to 30/09/2020 specified in the notice to deliver.
COTAX does not link the superseding dormant period ended 30/06/2019 to the Revenue Determination ended 30/09/2019, even though both end in the period 01/10/2018 to 30/09/2019 specified in the notice to deliver.
That is because COTAX does not link a superseding dormant period if there is a charge on the superseded AP. The Revenue Determination ended 30/09/2019 is therefore stranded, that is, stored without a link.
By filing its returns, the company has demonstrated that there is no AP ending in the period specified in the notice to deliver. The Revenue Determination for the period 01/10/2018 to 30/09/2019 is therefore of no effect. You need to use function RAMA (Record/Amend Assessment) to reduce it to nil.
Although the company was strictly still liable to deliver a dormant return for the specified period, you should discharge the penalty determinations on appeal using function PPEN (Prepare Penalty Determination). For more information see COM100000 onwards.