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HMRC internal manual

Company Taxation Manual

CTSA: Loans to participators: CTPF - late payment interest

Interest under TMA70/S87A is charged on outstanding ICTA88/S419 liability from the due date until the earlier of:

  • payment of the tax (TMA70/S87A (1)), and
  • the date that the loan or part of it is repaid, (or released or written off on or after 6 April 1999) (TMA70/S109 (3A)).

This remains the case even when Section 419 (4A) defers relief under Section 419 (4), see CTM61605 onwards.