CTM95310 | CTSA: Revenue determination: Timing
From HM Revenue & Customs · Company Taxation Manual
FA98/SCH18/PARA36 (2)
If you can ascertain the filing date for the return you can make a Revenue determination at any time after that date.
If you cannot ascertain the filing date for the return you can only make a Revenue determination after the later of:
18 months after the end of the period specified in the notice to deliver,
and
three months after the day of the service of the notice.