Corporation tax, VAT, PAYE/NIC, SDLT, ERS, R&D claims. Drives the tax-deed scope.

• III.1

  Obtain corporation-tax computations and CT600 returns for the last six years.[CTA 2009]

  Severity A
• III.2

  Identify any open HMRC enquiries, discovery assessments or pending litigation.

  Severity A
• III.3

  Confirm tax-losses carried forward and any restriction on use (CIR, group, change-of-ownership).

  Severity B
• III.4

  Review group-relief surrenders / claims for the last six years.

  Severity B
• III.5

  Review R&D tax-credit claims: methodology, supporting file, advance assurance.[HMRC R&D]

  Severity A
• III.6

  Confirm any Patent Box election and supporting computation.

  Severity C
• III.7

  Obtain VAT returns for the last four years; reconcile to ledger.

  Severity B
• III.8

  Confirm partial-exemption methodology, capital-goods scheme and option-to-tax positions.

  Severity B
• III.9

  Confirm PAYE/NIC compliance: P11D, IR35 status determination statements, RTI filings.

  Severity B
• III.10

  Review off-payroll engagements and SDS evidence for each consultant.

  Severity B
• III.11

  Confirm any HMRC PAYE or VAT inspection in the last six years and outcome.

  Severity B
• III.12

  Obtain SDLT returns and confirm filing for each historic property acquisition.

  Severity C
• III.13

  Review employment-related securities (ERS) returns, EMI option grants and 90-day notifications.

  Severity A
• III.14

  Confirm EMI option grants meet qualifying-trade and individual-limit conditions.

  Severity A
• III.15

  Identify any disguised-remuneration or loan-charge exposures.

  Severity A
• III.16

  Review transfer-pricing documentation and master/local file requirements.

  Severity B
• III.17

  Confirm any tax clearances obtained (s.701, s.138 TCGA, advance pricing agreement).[TCGA 1992]

  Severity B
• III.18

  Identify any tax exposures in dormant or recently-struck-off group entities.

  Severity C
• III.19

  Confirm CIS compliance for any construction-sector activity.

  Severity B
• III.20

  Confirm gross-payment status under CIS where relevant.

  Severity C
• III.21

  Obtain tax-deed draft and reconcile scope to identified exposures.

  Severity A
• III.22

  Confirm any exit-charge or de-grouping considerations under the proposed deal structure.

  Severity ABuy-side