COM23171 - Assessing: CTSA assessments: revenue determinations (Action Guide)
Source: gov.uk (2025-08-12)


To make, reduce to nil, or reinstate a Revenue determination, consider steps 1 - 25 below.

The guide is presented as follows.

Identifying cases for potential revenue determination (#identifying)

Step 1

Initial actions (#initial)

Steps 2 - 7

No determination required (NDR) (#no)

Step 8

Making a revenue determination when no return delivered (#making)

Steps 9 - 17

Making a revenue determination for an outstanding period (#outstanding)

Steps 18 - 22

Reducing a revenue determination to nil (#reducing)

Step 23

Reinstating a revenue determination (#reinstating)

Step 24

Identifying cases for potential revenue determination

1. Unless you have identified a case that needs a revenue determination because there is an outstanding period, use function DRNR (Determination Required No Return List) to see cases where no return has been logged and no determination made 18 months after the end of an Accounting Period (AP).

Initial actions

2. Use function TAXW (Taxpayer Worklist) to find any work list entries that you need to deal with before or after issuing the revenue determination.

3. Review any available information to establish the status of the company, including using the Companies House website to establish that the company is still on the Register and whether accounts have been submitted and decide whether you need to make any changes to the Accounting Period (AP) record.

4. Do not make a revenue determination if the company is dormant, is in liquidation because of a winding-up order, either compulsory or creditors’ unless you know of a specific liability for the AP (as HMRC is unlikely to receive payment towards any outstanding CT debt), has been struck-off or has ceased.

5. If the company is new and has not returned form CT41G, there will be no established pattern of APs. Consider telephoning the company’s agent or the company itself to find out the correct AP dates. Doing that now may avoid later complications with the AP record.

6. If you need to update the company’s COTAX record, select the [Options] button in function DRNR and on the next screen enter the function MAPD (Maintain AP Dates) to record a period of dormancy or any other changes to the company’s AP record or function ACTP (Amend CT Payer Details) to record the date of liquidation, striking off, or cessation.

7. Use function VPPD (View Payment and Posting Details) to check the payment position. You need to ensure that the determination is large enough to cover any payments made and does not create an overpayment. If the company pays the revenue determination, you cannot raise another one, nor make a discovery assessment without evidence of a loss of tax to the Crown.

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No determination required (NDR)

8. If, having considered all the relevant information, you decide that no determination is required, use the ‘prepare a revenue determination’ option in function RAMA (Record/Amend Assessment) to set the ‘NDR’ signal and select the ‘no penalty required’ option presented to you at the end of the function or use function MPEN (Maintain Penalty Signals) if the penalty option screen isn’t displayed.

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Making a revenue determination when no return delivered

9. If you decide a determination is required, use the ‘prepare a revenue determination’ option in function RAMA (Record/Amend Assessment) to make the determination.

10. The following screen, COT122N is initially displayed in short form. You can make an estimate for the following, depending on the AP start date:
- Trading profits.
- Trading losses brought forward.
- Annual payments not taxed or Schedule D Case III.
Alternatively, you can enter one figure for total profits.

11. If you want to assess a particular source of income or gain not available in the short form, select the [Switch to Full] button to see the full form and enter the amount of the income or gain.

You should avoid making a revenue determination that includes only S455 Corporation Tax Act (CTA) 2010 liability (close company loans and arrangements to confer benefits on participators). If you do so and subsequently agree that the company does not need to submit a return, COTAX may not allow you to reduce the revenue determination to nil.

12. When you have finished making your entries select the [OK] button.

13. If, exceptionally, your entries include carry-backs, COTAX shows them to you in summary form on the next screen and you can accept the carry-backs as shown or amend the interest effective date of any carry-back and the order in which the carry-backs are processed.

14. Whether or not your entries include carry-backs, COTAX then displays a screen for you to confirm the summary determination details. You can:
- enter a free format message to be shown on the printed output
- tell COTAX if, and when, a determination has been manually issued
- choose to suppress assessing output
- review the company’s quarterly instalment payment (QIP) status
15. Set the ’quarterly instalment payment’ signal.

If the value of the signal is ‘potential’, you must decide what the company’s QIP status is and change the signal to ‘Yes’ or ‘No’. You need to do that because the revenue determination has effect as if it were a self assessment, unless and until the company delivers its return and self assessment within the relevant time limit, so you must decide on the company’s QIP status for the AP.

Do not set the signal to ‘Yes’ if the company has made a return for the immediately preceding AP and it was not a large company for that AP. Only set the signal to ‘Yes’ if it is reasonable to contend that the instalment provisions should apply, on the basis of the figures in the determination and other information you hold.

If you set the indicator to ‘Yes’, and you need to issue a determination that tax is payable in instalments, enter a free format message in function RAMA such as ‘Paragraph 38(2) Schedule 18 Finance Act 98 - the tax charged is payable by instalments on the dates provided by regulations made under Section 59E Taxes Management Act (TMA) 70’.

16. COTAX compares your determination figures with the value of the ’quarterly instalment payment’ signal and displays a warning message if there is an apparent inconsistency based only on the figure of profits in the determination. COTAX makes its calculation as if there is no franked investment income (for APs ending on or before 31 March 2023)/franked investment income/exempt ABGH distributions (for APs ending on or after 1 April 2023) and the company has no 51 percent companies (for APs ending on or before 31 March 2023)/associated companies (for APs ending on or after 1 April 2023). For more information see COM23172. (https://www.gov.uk/hmrc-internal-manuals/cotax-manual/com23172)

17. When you amend the ‘quarterly instalment payment’ signal, COTAX displays an advisory message telling you to review the signal for later APs using function MAPS (Maintain AP Signals). for more information see COM23173 (https://www.gov.uk/hmrc-internal-manuals/cotax-manual/com23173).

Finish making the revenue determination, deal with the penalty position and use function MAPS to review the ‘QIP’ signal for later APs.

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Making a revenue determination for an outstanding period

18. If you have received a return for an Accounting Period (AP) ending in the period specified in a notice to deliver but you think there is an outstanding period, use function DAPD (Display AP Details) to check whether there is an existing AP that matches the outstanding period.

If there is not a matching AP, use function MAPD to create it and make any other changes needed to the company’s AP record.

19. Once the outstanding period has been created on the company’s AP record, function RAMA allows you to make a revenue determination for it and the outstanding period may, in due course, appear on the DRNR work list.

20. Before you make the determination, check the relevant time limits to confirm that you are legally entitled to do so. Unless the filing date for the outstanding period is ascertainable, you normally have to wait until 30 months after the end of the period specified in the notice to deliver. For more information see COM23174. (https://www.gov.uk/hmrc-internal-manuals/cotax-manual/com23174)

21. Use the ‘prepare a revenue determination’ option in function RAMA (Record/Amend Assessment) to make a revenue determination for the outstanding period. To record a value entered on screen COT121N as an estimate you will need to enter "E" in the estimate field.

22. Deal with the penalty position, normally by using function PPEN (Prepare Penalty Determination).

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Reducing a revenue determination to nil

23. If a determination becomes ‘stranded’, that is, stored without a link (Word 30KB) (http://www.hmrc.gov.uk/gds/com/attachments/link.doc), you may need to intervene. If you decide that the determination is of no effect (for example, where the company establishes that no return is due in response to the notice to deliver), use the ‘reduce determination to zero’ option in function RAMA to reduce the determination to nil.

Reinstating a revenue determination

24. If you need to reinstate a determination, for whatever reason, use the ‘reinstate determination’ option in function RAMA (Record/Amend Assessment).