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Many businesses will be aware that, due to the impact of the coronavirus (COVID-19) pandemic, Companies House provided companies with a 3-month filing extension by virtue of the "Corporate Insolvency and Governance Act 2020" and "Companies etc. (Filing Requirements) (Temporary Modifications) Regulations 2020".

Despite this extension, there is currently no formal process for obtaining an extension from HMRC to the statutory filing deadline for corporation tax returns. 

Where a business has a filing deadline which it is unable to meet due to the impact of COVID-19, we recommend the business proactively contacts HMRC to discuss their circumstances, as it may be possible to agree a deferral of the issue of late filing penalties.

Where businesses have already filed a tax return after their filing date, HMRC has issued some guidance which indicates that where a delay in submitting a corporation tax return on time was due to the impact of COVID-19 this will qualify as a reasonable excuse for submitting the return late - and so no late filing penalty should be charged. (https://www.gov.uk/tax-appeals/reasonable-excuses)

HMRC has indicated within their guidance that unsigned accounts that do not meet the Companies Act will not be accepted by HMRC, nor will accounts that have not been iXBRL tagged. Companies will therefore need to ensure that when their corporation tax returns are submitted to HMRC, they are accompanied by a valid set of accounts.