When a close company enters liquidation, it does not become a close investment-holding company for the period immediately after liquidation if it was not one before liquidation. Therefore, it may be subject to the small profits rate or may claim marginal relief if applicable. However, in subsequent periods, it is considered a close investment-holding company and is subject to the full tax rate.
If you complete box 4 of the CT600 as type "3", indicating a company in liquidation, and also fill in box 329 to claim the small profits rate or marginal relief, you will encounter validation error 9415. The Customer Support team has confirmed with HMRC that you should not mark the CT600 as company type “3” for the period after liquidation.
To complete the CT600 correctly and apply the appropriate tax treatment using ONESOURCE CT, keep the company type as it was immediately before the liquidation to avoid the e-filing error mentioned above. For any periods that follow, set the Type of CT return form flag on the Information for the return sheet to “In liquidation” to ensure the CT600 is accurate and the correct tax treatment applies.