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HMRC internal manual

Enquiry Manual

Interest: Mitigation

TMA 70/S86

TMA 70/S87

TMA 70/S87A

There is no specific power to mitigate interest. Only the general “collection and management” responsibility of the Commissioners for HMRC under S5 CRCA 2005 is relevant.

Where there is an objection to an interest charge this should be referred to the DMB Interest Review Unit following the guidance in

  • SAM for an SA interest charge
  • COM for a company case

In a contract settlement interest can be reduced if there has been unreasonable HMRC delay within the terms of the “Complaints and putting things right” factsheet. Where a taxpayer presses a complaint that excessive HMRC delay has caused or contributed to the interest charge seek advice - see TAA - caseworker service for technical queries.