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HMRC internal manual

COTAX Manual

Background: company taxation overview: group payment arrangements

This subject is presented as follows.

Eligible companies
Relevant APs
Administration and application forms 


The statutory basis for Group Payment Arrangements, introduced at the same time as CTSA, is in Section 36 FA 1998. HM Revenue and Customs are empowered to offer companies in a group the facility to have one company pay tax on behalf of all of them.

The aim of Group Payment Arrangements is to help groups containing large companies manage any uncertainty over the amount of the individual companies’ tax liabilities in the period between:

  • the liabilities falling due and
  • delivery of the individual companies’ tax returns.

The arrangements mean that groups still have to pay the right amount of CT at the right time, but in estimating what is due to be paid they can forecast for the participating companies as a whole, rather than for each individual company and pay on that basis, rather than having to divide payments between the companies in the group.

The arrangements mitigate the effect on a group of the differential interest rates on overpaid and underpaid tax up until the payments for a group payment period have been allocated out of an arrangement to the individual participating companies. Thereafter, any movements of monies between participating companies are subject to the normal rules, for example S963 CTA 2010 claims (formerly S102) or Reg 9.

For full details of the working arrangements for group payments, see COM96000 onwards.

Eligible companies

Companies eligible to enter into the arrangements are:

  • parent companies and their 51 per cent subsidiaries
  • the 51 per cent subsidiaries of those subsidiaries, and so on.

Not all companies in the group need be resident in the UK, but the company nominated to pay on behalf of the participating companies (the nominated company) must be resident or based in the European Union (EU). UK subsidiaries of overseas parent companies and UK branches of non-resident companies can come within an arrangement.

Not all members of the group need be covered by the Group Payment Arrangement and a group may apply to set up more than one arrangement for different sub - sets of companies in the group. The participating companies have to make up accounts to the same date as the nominated company.

Only companies that have delivered returns and paid tax due in respect of their last but one AP, and new or newly activated companies, are eligible to be covered by an arrangement.

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Relevant APs

The arrangement relates to periods of account of the nominated company. The periods cannot be longer than 12 months.

Each period must be an AP of each of the participating companies.

A company that is newly formed, newly activated or newly acquired by the group will, by agreement, be able to be covered by the arrangement, provided it aligns its accounting date with that of the nominated company. Such a company cannot be covered by the arrangement in respect of an AP that began before the period of account covered by the arrangement.

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Administration and application forms

Group Payment Arrangements are set up and administered by Group Payment Team at Accounts Office.

Groups wanting further information or an application form must contact the Group Payment Team or look on the HMRC website.

The address and telephone number of the Group Payment Team is:

Group Payment Arrangement Team
Debt Management and Banking
St Mungo’s Road
G67 1YZ

Telephone - 03000 583947
Fax Number - 03000 583901 or 03000 583902

See COM30021 for legislation applying to this subject.