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HMRC internal manual

Company Taxation Manual

CTSA: group payment arrangements: introduction

TMA1970/S59F provides for group payment arrangements. It allows the Board to offer companies in a group the facility to have one company pay tax on behalf of all of them.

The arrangements mean that:

  • groups still have to pay the right amount of CT at the right time,
  • when estimating what is due to be paid, groups can forecast for the participating companies as a whole rather than for each individual company,
  • the effect on a group of the differential in interest rates on over and underpaid tax is mitigated.

A group payment arrangement is more flexible than a repayment surrender under CTA2010/S963 for neutralising the effect of the credit and debit interest rates differential.

Note: A group payment arrangement transfers the responsibility for making payments of tax to the nominated company not the actual tax liability of the participating companies. (See CTM97420 for the definitions of nominated company and participating company).

Group payment arrangements are machinery provisions only and do not affect the computation of any company’s liability to tax.

They do not prevent a company from being pursued for payment of tax if legal proceedings to enforce payment are required after the closing date. (For a definition of ‘closing date’ see CTM97500).