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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: repayment - intra-group surrender - FA89/S102

Groups of companies can minimise their exposure to interest on overdue tax by surrendering overpayments within the group.


  • a company (the surrendering company) is a member of a group, and
  • is entitled to a repayment of CT or IT or a payment of tax credit,

it can give notice jointly with another member of the group (the recipient company) that a specified amount of the refund is to be surrendered to the recipient company.

If joint notice is given in respect of an amount of tax:

  • the recipient company is treated for interest purposes as having paid the tax, and
  • the surrendering company is treated for interest purposes as though the tax had been repaid to it,

on the due date for the accounting period to which the tax relates, unless the repayment is of tax paid late in which case the date of payment is used.

The recipient company is also treated as having paid any interest under TMA70/S87A that may have been paid by the surrendering company on the amount of refund surrendered.

For this provision to apply:

  • both the surrendering and recipient companies must be members of the group (for group relief purposes) from,
    • the first day of the accounting period to which the refund relates to
    • the date on which the notice is given,
  • the accounting period to which the refund relates must be the same for both companies,
  • the joint notice must be given to the Inspector dealing with the surrendering company before the refund is made.

Note: a refund made by payable order is not ‘made’ until the payable order has been passed through a bank.

The recipient company can itself surrender the refund (or part of it) to another group company, provided the above conditions are met.

For the effect of a surrender on the calculation of a tax-related late filing penalty see CTM94080.

When either the surrendering or the recipient company is a quarterly instalment payer see CTM92740.