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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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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 in a country 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 ICTA88/S584 and TCGA92/S279 to have unremittable income and chargeable gains assessed for the accounting period during which they become remittable - see IM4150+ for further details.