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HMRC internal manual

Company Taxation Manual

Corporation Tax self-assessment (CTSA): the payment obligation: payment for surrendered tax refund

Any payment made between the surrendering and recipient companies in respect of a transferred tax refund is treated as having no tax consequences, that is:

  • it is not taken into account in computing profits or losses of either company for CT purposes, and
  • it is not regarded as a distribution or a charge on income.