Commentary

A4.632 Interest on overpaid tax and tax paid early—corporation tax

Administration and compliance

A4.632 Interest on overpaid tax and tax paid early—corporation tax

A4.632 Interest on overpaid tax and tax paid early—corporation tax

Interest is payable on payments to a company representing1:

  1.  

    (a)     repayment of corporation tax overpaid

  2.  

    (b)     repayment of income tax deducted at source

  3.  

    (c)     payment of R&D tax credit2

  4.  

    (d)     payment of vaccine research tax credit3

  5.  

    (e)     payment of land remediation tax credit (see D1.513, D1.517)4

  6.  

    (f)     payment of film tax credit, television tax credit, video game tax credit, theatre tax credit or orchestra tax credit5, or

  7.  

    (g)     payment of first-year tax credit (which will not be available in relation to expenditure incurred on or after 1 April 2020, see B3.324H)6

  8.  

    (h)     payment of museums and galleries exhibition tax credit7

The interest is payable without deduction of tax but, is chargeable to corporation tax under the loan relationship rules8. See D1.743

Material date

Interest is paid from the 'material date', as follows:

  1.  

    •     for a payment under (a) above, interest runs from the later of:

    1.  

      –     the date on which the tax was paid, and

    2.  

      –     the due and payable date (see A4.607, D1.1345),

  2.  

    to the date on which the repayment order was issued. Where the tax was paid on different dates, the repayment is treated as relating as far as possible to payments on later dates9

  3.  

    •     for a payment under (b) above, interest runs from the day after the end of the accounting period in which the relevant payment was

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