Commentary

A7.248D Accelerated payments and group relief

Administration and compliance

A7.248D Accelerated payments and group relief

A7.248D Accelerated payments and group relief

Where a company has losses or certain other amounts that derive from arrangements that meet the criteria, an APN would not require it to pay over any amounts at that point because it may have no actual tax to pay when the dispute is resolved. However, it could surrender some or all of those amounts as group relief so that the cash timing benefit passes to other companies in the group. Changes made to the APN rules1 with effect from 26 March 2015 prevent those amounts being surrendered and claimed while the dispute is in progress, so that the relevant cash amount can be held by the Exchequer during the

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