Corporation Tax Act 2010 section 357YA

Charge to corporation tax on restitution interest

Section 357YA establishes that restitution interest received by a company is subject to corporation tax on income, while excluding charitable companies from this charge.

• Restitution interest arising to a company is chargeable to corporation tax on income
• Charitable companies are specifically excluded from this charge
• The charge applies to interest paid by HMRC when tax has been unlawfully collected and must be repaid
• The section was introduced by Finance (No. 2) Act 2015 and amended in 2017 to add the charitable company exemption