Commentary

A7.248D Accelerated payments—group relief

Administration and compliance

A7.248D Accelerated payments—group relief

A7.248D Accelerated payments—group relief

HMRC has the power to issue an accelerated payment notice (APN) to any taxpayer for whom there is an open enquiry, or a matter is under appeal where certain conditions are met1.

The regime applies to income tax, capital gains tax, corporation tax (including amounts chargeable as or treated as corporation tax), the apprenticeship levy, inheritance tax, stamp duty land tax, annual tax on enveloped dwellings (ATED)2

For an overview of the APN provisions, including the conditions that must be met for one to be issued, see A7.248. For a discussion of the APN provisions as they apply to partners in partnership, see A7.248C.

This article discusses the interaction between the APN and group relief for companies.

Interaction between 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

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