An error resulted in an overstatement of turnover and profit in the accounts for our client for the period from 4 Dec 2012 to 31 May 2014. The restated figures are shown in the accounts for the year to 31 May 2015, so I had to submit amended CT600s for the period in question. The online system rejected the first 12 month period as being out of time.
I checked the legislation that I am aware of in respect of the deadline for filing an amended CT600: Paragraph 15(4) of Schedule 18 of FA1998, which states that “Except as otherwise provided, an amendment may not be made more than twelve months after:
(a) the filing date, or
(b) in the case of a return for the wrong period, what would be the filing date if the period for which the return was made were an accounting period.”
with the filing date being twelve months from the end of the company's relevant period of account, where that period is not longer than 18 months (Para 14), as is the case here. This is also the only deadline referred to in the guidance on the Gov.uk site and in Revenue Manuals COM23010 and COM130030 for amending a CT600.
I called HMRC, who stated that an amendment needs to be submitted "within the statutory time limit of 2 years after the Accounting Period end date or 12 months after the filing date." When I asked for a statutory reference, they simply emailed the GOV site which only mentions the latter, but they restated their "statutory time limit" as quoted above.
I have submitted the amendment by post, but does anyone know of a legislative restriction for amendments to 2 years after the AP end date that I (and CTA syllabus) have missed? Or is this another case of HMRCs internal guidance not matching the legislation?