Corporation Tax Act 2010 section 964

Effects of surrender of tax refund

Section 964 sets out the corporation tax consequences for both the surrendering company and the recipient company when a tax refund is surrendered within a group under section 963.

• The recipient company is treated as having paid corporation tax equal to the surrendered amount on the relevant date, for all corporation tax purposes except late filing penalties
• For late filing penalty purposes, the recipient company is treated as having paid the tax on the date the surrender notice is given, not the relevant date
• The surrendering company is treated as having received a tax repayment equal to the surrendered amount on the relevant date
• Where the surrendered refund was a repayment of corporation tax, any interest the surrendering company paid in connection with that tax is treated as having been paid by the recipient company