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CTM95390 | CTSA: Revenue determination: Time limit

From HM Revenue & Customs · Company Taxation Manual

You cannot make a Revenue determination later than three years after the date on which you could first make it (FA98/SCH18/PARA36 (5) and FA98/SCH18/PARA37 (4)).

See CTM95310 and CTM95360 for guidance on when you can first make a Revenue determination.