TaxSource Total

Here you can access summary of the key current tax developments in Ireland, the UK and internationally as reported by Chartered Accountants Ireland

The report of key tax developments are displayed per year, per month, by Ireland, the UK or International and by report title

Corporation tax loss reform – have you already submitted corporation tax returns affected?

A recent Stakeholder’s Forum meeting with HMRC discussed corporation tax loss reform from 1 April 2017 and what action a company may have to take if it is has already submitted a corporation tax return and computation for an accounting period ending after the change which is affected by the changed legislation.

The legislation which changes the rules for corporation tax loss reform is contained in the Finance (No. 2) Act 2017 which received Royal Assent last month.

HMRC’s initial advice is that if a company has submitted a corporation tax return and computation for an accounting period ending after 1 April 2017 which is impacted by the retrospective coming into effect of the changed legislation, it is likely that such returns and computations will have to be resubmitted to HMRC.

The potential impact of a second submission on the window during which HMRC can open an enquiry has not yet been addressed by HMRC. We’ll update you when we have more on this story.

HMRC have also now published the second tranche of draft guidance on the revised legislation.

Readers are reminded that the second Finance Act of 2017 contains some major changes to the UK tax regime which have retrospective effect. In addition to corporate tax loss reform, this includes the new rules for corporate interest deductions and the new deemed domicile concept for income tax, capital gains tax and inheritance tax, amongst others.