INTM436090 - Transfer pricing before CTSA
CT Pay & File aspects
Before Corporation Tax Self Assessment there was Corporation Tax Pay & File (CTPF). There are obvious and distinct differences for transfer pricing between CTPF periods (during which ICTA88/S770 applied) and CTSA periods (during which Sch 28AA applied). Given the nature of transfer pricing cases, however, it may be that there are cases still being worked which include periods before CTPF was introduced.
- CTPF applied to accounting periods ending after 30t h September 1993.
- CTSA applies to company accounting periods ending on and after 1 July 1999.
The distinction between pre-CTPF periods and CTPF periods is significant in relation to:
Assessing - assessments are not normally raised under CTPF until assessable figures are agreed, unless there are delays, disputes, approaching time limits or some other issue requiring a protective assessment and/or an appeal. Prior to CTPF an estimated assessment would routinely have been raised at an early stage in order to ensure prompt submission of the return. Inspectors should always ensure that a normal time limit assessment is raised for any enquiry year which is close to going out of date. The interaction of assessment and direction is discussed in detail at INTM436050.
Directions - see INTM436050
