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FA98/SCH18/PARA4 provides explicitly that ‘delivery� of the return means delivery of all the:

• information,
• accounts,
• statements, and
• reports,

required by the FA98/SCH18/PARA3 notice.

This ensures consistency in the interpretation of ‘delivery of the return� in relation to all the CTSA provisions that bear upon it.

Thus, if a company delivers a completed return form but fails to deliver a copy of its accounts and computations, it does not satisfy the filing obligation and the enquiry ‘window� does not open. This includes when a company has delivered a voluntary return. See EM1510 for guidance about enquiries into company tax returns and the time limits for opening an enquiry.

‘Informal returns�

Liquidators may merely send a letter or statement outlining the present state of the company instead of the CT600, accounts and computations. However, an ‘informal return� in the form of a mere letter or statement is not in the ‘prescribed form� for the purposes of TMA70/S113, and does not comply with FA98/SCH18/PARA3.

Officers may accept such letters or statements in order to avoid unnecessary pursuit by Debt Management. But if you are dissatisfied with such an ‘informal return� you should ask the liquidator to deliver a return that does comply with Paragraph 3. You will need to point out that the penalty provisions contained in FA98/SCH18/PARA17 and 18 will apply if no return is delivered. You cannot open an enquiry until you receive a return that complies with Paragraph 3.