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HMRC internal manual

Company Taxation Manual

Groups & consortia: consortia - group income - late elections

The parts of ICTA88/S247 relating to payments of dividends were repealed from 6 April 1999 onwards. The remainder of Section 247 was repealed by FA01 in relation to payments of interest or charges made after 11 May 2001.

Where a company asks that an election should be treated as applying to:

  • dividends, or
  • charges or loan relationship interest,

paid before the election became effective, you can accept the request where all the following conditions are met. The conditions are that:

  • there is no disturbance to assessments which have become final and conclusive, or claims to which effect has already been given,
  • you are satisfied that an election coming into force before the time of the payment in question would have remained valid at that date,
  • you are satisfied that the omission to make an election in advance of the making of the payment is attributable to illness, genuine oversight or some similar cause,
  • you are satisfied that the company receiving the dividends or other payments agrees they are treated as group income or income received without deduction of IT.

Submit any cases of difficulty to CTIS (Technical).