HMRC has republished its Guidance on Follower Notices and APNs, with changes made to deal with companies with disputed losses claims.
HMRC defines the term “asserted surrenderable amount”, as an amount of a surrenderable loss which an HMRC officer believes will not be available for surrender if the relevant planning proves ultimately to be unsuccessful. After receiving an APN, a company must withdraw
its consent to surrender a loss and notify the claimant company of the same. The claimant company must then amend its returns and pay corporation tax which then falls due.
The Guidance indicates that if the planning is later found to work, a new group relief claim can be submitted within 30 days of the decision confirming the same.
The Guidance can be read here.