Corporation Tax Act 2010 section 977

Notice requiring payment of unpaid tax

Section 977 enables HMRC to serve a notice on a company related to a non-UK resident taxpayer company, requiring it to pay all or a proportion of the taxpayer company's unpaid corporation tax within 30 days.

• An HMRC officer may serve a notice on a related company requiring it to pay the full amount of unpaid corporation tax, or in a consortium case, only the proportion determined under section 979.
• The notice must state the unpaid tax amount, the date it first became payable, and the amount the related company is required to pay.
• The notice is treated as if it were a notice of assessment, meaning HMRC can recover the amount (plus interest) and the company can appeal against it as if the tax were its own liability.
• A "consortium case" arises where the related company does not fall within section 976(1)(a) — that is, it is not a 51% subsidiary or parent of the taxpayer company but is instead connected through a consortium arrangement.