Commentary

D2.729 Payment and recovery of DPT

Corporate tax
Corporate tax | Commentary

D2.729 Payment and recovery of DPT

Corporate tax | Commentary

D2.729 Payment and recovery of DPT

When a charging notice has been issued to a company, the DPT must be paid within 30 days of the day the notice is issued. The tax cannot be postponed on any grounds so is payable irrespective of any ongoing review or appeal in respect of the notice1. A penalty can be applied if payment of DPT is late2. (See A4.560 for details of the late payments penalties regime.) Any payment of DPT is not allowed as a deduction or any other relief when calculating income, profits, or losses for any tax purposes and any amounts paid are not to be treated as a distribution3.

The total amount of DPT charged includes an amount of 'true-up interest' which is charged on the DPT amount and calculated by reference to a notional period which runs from the date beginning six months after the end of the accounting period to which the charge relates and ends with the day the notice to impose the DPT charge is issued4. The interest is charged at 2.5% per annum from 6 April 2017 (3% per annum for the period from 1 October 2015 to 5 April 2017)5.

Late payment interest is also charged where DPT remains unpaid. For further details on interest on late paid tax and the harmonised interest regime see A4.620.

The corporation tax legislation which applies for the assessment, collection and recovery of corporation tax (including interest on tax) to non-resident companies6 (D4.121) applies, with some modifications,

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