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HMRC internal manual

Debt Management and Banking Manual

Interest: Interest Review Unit (IRU): Corporation Tax (CT): CTSA Group payment arrangements

Group Payment Arrangements (GPAs) came into effect for Accounting Periods ending on or after 31 December 99. This offers a group of companies the option of one company being able to pay tax for all of them.

The aim is to help groups containing large companies to manage the uncertainty over the amount of the individual companies’ tax bills in the period between the Accounting Period end and the due dates for payment and filing their tax returns. The arrangements mean that, while groups still have to pay the right amount of CT at the right time, they can predict the amount due for the group as a whole, and pay on that basis. It is only when they have sent tax returns for all companies within the arrangement that they are asked to divide the payments they have made. More information about Group Payment Arrangements and how they are managed can be found in

  • ‘A Guide to Group Payment Arrangements’; A group may object to interest being charged on the grounds that:

  • they want to change the way they originally divided the payments;
  • they want to change the way we divided the payments; or
  • the way the payments have been divided is wrong.When the arrangement is closed, the group is asked how to divide their payments. The payments are allocated strictly in line with their instructions. If they do not instruct how the payments are to be divided within 30 days of being asked, HMRC send proposals for dividing the payment. The group then have a further 30 days to agree or confirm their changes. It is only if they do not reply that the proposals are applied.

An objection to the interest charged will only be considered, if the division actually made:

  • does not agree with the group’s division; or
  • was made by HMRC before the time limit for disagreeing the proposals had passed.Normally, when money is reallocated to the correct place, the interest position will be corrected. But where this can no longer be done, theoretically recalculate the interest as if the payments had been correctly divided. Give up any excess interest.