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HMRC internal manual

Company Taxation Manual

CTSA: group payment arrangements: late filing penalties

If any company in a group payment arrangement:

  • files its return late enough to incur a tax-related penalty under FA98/SCH18/PARA18 (see CTM94000 onwards),


  • there is a payment shortfall in the arrangement at the date on which the penalty is incurred,

the apportionment that the nominated company makes cannot relieve a late filing company of its liability to the tax-related penalty if there was an overall shortfall in the payments made under the group payment arrangement.

The payments made under a group payment arrangement are apportioned:

  • for the purpose of calculating such a penalty only,


  • without prejudice to the actual allocation of the money to the individual company records,


  • to companies that have not incurred a tax-related penalty,


  • to companies that have incurred a tax-related penalty of 10%,


  • to companies that have incurred a tax-related penalty of 20%.

COTAX cannot carry out this apportionment. If a company within a group payment arrangement is liable to a tax-related penalty you need to review carefully how COTAX has calculated the penalty. (See the On-line Company Tax Manual (COM) in the Penalties business area for guidance.)