The main points in the summary of response that are relevant to our sector are as follows:
there is a need for clarity and assurance on the design and timing of MTD for CT - with larger business taking 2 to 5 years to prepare and fund changes
concerns were raised about the tagging of data at transactional level, the alignment of filing dates for statutory accounts and company tax returns, and the inclusion of charities within the scope of MTD for CT
It is envisaged that companies will be able to use more than one software program to meet the totality of the MTD requirements and that there will be some form of digital links, as with MTD for VAT
clarity will be provided by HMRC on the information required for a quarterly update once further work is completed.
it is acknowledged that an entity’s tax position may change across the year and that a quarterly update, whilst an indication of business performance and record keeping, may not provide an accurate assessment of their final liability.
the majority of respondent supported a 1 month filing deadline for quarterly returns but it was accepted that other suggestions had merit (BUFDG didn’t agree with a monthly submission deadline given that it is likely to clash with the preparation of the VAT return)
the Government would be interested to explore further options to shorten the timescales between the submission of statutory accounts and company tax returns.
tagging at transactional level is more complex considering how many transactions an entity may have. HMRC need to justify why tagging is needed by clearly outlining the benefits to businesses.
there is going to be further work with the charity and not-for -profit sector and smaller charities may be exempt from submitting quarterly returns
The discussion regarding the Charity sector is set out in Section 8 – Special Cases and Exemptions. This section is worth a read for those of you involved in the CT return preparation process.
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07 December 2021 
Andrea Marshall, Tax Specialist
