Section 978 | Time limit for giving notice

(1)A notice under this Chapter must be served before the end of the period of 3 years beginning with the date when the liability of the taxpayer company to corporation tax for the accounting period in question is finally determined.

(2)If the unpaid tax is charged as a result of a determination under paragraph 36 or 37 of Schedule 18 to FA 1998 (determination where no return delivered or return incomplete), the date mentioned in subsection (1) is taken to be the date when the determination is made.

(3)If the unpaid tax is charged in a self-assessment, the date mentioned in subsection (1) is taken to be the latest of—

(a)the last date when notice of enquiry may be given into the return containing the self-assessment,

(b)if notice of enquiry is given, 30 days after the enquiry is completed,

(c)if more than one notice of enquiry is given, 30 days after the last notice of completion,

(d)if after such an enquiry an officer of Revenue and Customs amends the return, 30 days after notice of the amendment is issued, and

(e)if an appeal is brought against such an amendment, 30 days after the appeal is finally determined.

(4)If the unpaid tax is charged in a discovery assessment, the date mentioned in subsection (1) is taken to be—

(a)if there is no appeal against the assessment, the date when the tax becomes due and payable, or

(b)if there is such an appeal, the date when the appeal is finally determined.

(5)The reference in subsection (3) to a self-assessment includes a self-assessment that supersedes a determination (see paragraph 40 of Schedule 18 to FA 1998).