Corporation Tax Act 2010 section 357YV

Relationship of Part with other corporation tax provisions

Section 357YV establishes that the restitution interest charge takes priority over all other corporation tax provisions, ensuring that the same income is not taxed twice under different rules.

• Restitution interest taxed under this Part cannot be taxed again under any other corporation tax provision
• This includes an explicit override of Part 2 of the Finance Act 2012
• This Part takes precedence even over the loan relationships rules in section 464(1) of CTA 2009, which would otherwise have priority
• The provision prevents double taxation while ensuring restitution interest is always caught by these specific rules