My client made an election under S330 CTA 2009 for the period ended 31 December 2015, in December 2017. The election was as follows:-
We hereby elect under Section 330 of the Corporation Tax Act 2009 for the non-trading loan relationships debits in respect of the year ended 31 December 2015 to be treated as a debit for the accounting period in which the company begins to trade and to be brought into account in accordance with section 297(3) of the Corporation Tax Act 2009 (trading debits).
The non-trade relationship debits for the year ended 31 December 2015 amounted to £x,xxx.
Unfortunately, due to a late amendment to the Return and the amendment being overlooked, the figure quoted was incorrect. HMRC has rejected the election because of this.
Having reviewed S330, I'm not sure that quoting the figure was needed and therefore does the fact that it was quoted invaildate the election?