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HMRC internal manual

Company Taxation Manual

HM Revenue & Customs
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CTSA: group payment arrangements: payment of tax

Under group payment arrangements:

  • the nominated company undertakes to pay the CT liabilities of all the companies covered by the arrangement,


  • none of the companies covered by the arrangement has to individually pay its own CT,

during the period up to the closing date. (See CTM97500 for a definition of the closing date.) CT, in this context, includes any amount assessable or chargeable as if it were corporation tax within the definition of “tax” in Paragraph 1 of Schedule 18 to FA1998, including for example liability under CTA2010/S455 (loans to participators by close companies) and ICTA88/S747 (controlled foreign companies).

The nominated company undertakes to:

  • make payments of tax on the quarterly instalment payment due dates:
    • based on the most recent profits forecast of all the large companies in the arrangement (see CTM92500 onwards),


  • adjust the payments made throughout the quarterly instalment period if that forecast changes:
    • increasing or reducing payments as appropriate,


  • make top-up payments, where appropriate (see CTM92610),
  • pay the amount due on the normal due date from all participating companies:
    • including the total liability of any non-large companies,


  • the balance of liability of the large companies not payable by quarterly instalments during the transitional years.

The nominated company must make payments of CT under the group payment arrangement by BACS, CHAPS or bank giro credit. Changes in liability of a participating company after the closing date are its own responsibility, and do not fall within the group payment arrangement.