Taxation (International and Other Provisions) Act 2010 section 59Fโ€“59H

Arrangements for paying tax on behalf of group members and managed payment plans

Sections 59F to 59H, inserted into the Taxes Management Act 1970, deal with two mechanisms: group payment arrangements for corporation tax and managed payment plans for income tax, capital gains tax, and corporation tax.

  • An HMRC officer may agree arrangements allowing one company in a group (a parent and all its 51% subsidiaries) to pay corporation tax on behalf of some or all other group members, though each company's underlying tax liability remains unchanged.
  • Taxpayers may enter into managed payment plans, paying income tax, capital gains tax or corporation tax by instalments, provided the instalments paid before the normal due date are balanced in time value against those paid after it.
  • If all instalments under a managed payment plan are paid as agreed, the taxpayer is treated as having paid the full amount on the normal due date, removing exposure to late payment interest, penalties and surcharges.
  • If a taxpayer defaults on later instalments, they are still treated as having paid the earlier instalments on the due date, and HMRC may issue a notice excusing penalties or surcharges on specified post-due-date payments actually made.

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