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HMRC internal manual

Company Taxation Manual

Corporation Tax self-assessment (CTSA): the payment obligation: interest revision for unremittable overseas income or gains

Under TMA70/S92 where:

  • interest under TMA70/S87A would run on CT charged on income or chargeable gains arising outside the UK and
  • as a result of action of the government of that country, the income or gains cannot be remitted to the UK and
  • the Board have taken no action to collect the tax for the time being

then interest on that tax ceases to run under Section 87A from either:

  • the due and payable date, provided that the information necessary to satisfy the Board is supplied not later than three months after that date or
  • the date on which the information necessary to satisfy the Board is supplied, if this is later than three months after the due and payable date.

If a demand for the tax is subsequently issued, interest under Section 87A begins to run again from the date of the demand. If payment is made within three months of the date of the demand, any accrued interest is remitted under TMA70/S92 (3).

Companies can claim under TCGA92/S279 to have unremittable chargeable gains assessed for the accounting period during which they become remittable.

By claiming relief under CTA2009/S1275, companies can defer the period in which unremittable income is taken into account for corporation tax purposes.