9.7.1 Overview

The corporation tax rules take a similar approach and, in particular, distinguish between careless and deliberate conduct cases and those less culpable situations.

Law: FA 1998, Sch. 18, para. 61 to 65

9.7.2 Careless or deliberate cases

The key difference in corporation tax cases is that careless or deliberate conduct by a person who was, at the relevant time, a partner of the company is sufficient to exclude the company from the possibility of an extended time limit.

The term ‘relevant time’ is not defined and is thought therefore to mean the time when the allegedly careless or deliberate conduct took place.

Law: FA 1998, Sch. 18, para. 61(2)(c), 65(1)(c)

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