This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Company Taxation Manual

CTSA: Loans to participators: Late payment interest

TMA70/S87A (1)

Interest is charged on any outstanding CTA10/S455 liability from the due date until the earlier of:

  • payment of the tax (Section 87A(1)), and
  • the date that the loan or part of it is repaid, released or written off (TMA70/S109 (3A)).

For the purpose of applying the second rule, any tax that is unpaid at the date on which a repayment etc. occurs is assumed to be, as far as possible, Section 458 tax, rather than CT or tax under ICTA88/S747.

Even when relief is deferred under Section 458 (5) interest is only calculated until the date of repayment, release or set-off, see CTM61605 onwards. In such cases you should use form CT250(P) to tell the accounts office the date(s) to which interest should be calculated .

To find out more on late payment interest see the On-line Company Tax Manual (COM) “CTA10 S458 - Late Payment Interest” in the “Other Reliefs” section in the Claims/Reliefs business area.