On 14 May HM Revenue & Customs announced that, due to COVID-19, the usual 30 day deadline for notifying HMRC of an option to tax (“OTT”) would be extended from 30 to 90 days.
Less helpfully, they said that the period that this extension would run for was from 15 February to 31 May 2020. So, there’s only another 17 days of the extension left!
The extension of the 30 day rule is helpful where an OTT application now needs to have an effective date of between 15 February and 14 April, but does not appear to allow a sale that could have been a Transfer of a Going Concern (TOGC), as the rules for TOGC treatment require the notification to be with or submitted to HMRC on or before the relevant date of the transaction.
If you have any queries regarding this, please contact Ian Marrow, Director at Rickard Luckin at [email protected]