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HMRC internal manual

Company Taxation Manual

Residence: dual resident companies: early payment of charges on income

ICTA88/SCH17/PARA6 applied to the usual dual resident investing company whose interest payments are treated as charges on income. It deals with the situation where either interest has been paid before the due date or where arrangements have been made on or after 5 December 1986 (the date the proposed legislation was announced) to alter the due date.

Apply if necessary to CTIS (Technical) for archive guidance. See CTM34700.