CTM92800 - Corporation Tax self-assessment (CTSA): quarterly instalments: anti-avoidance - charge

If a company falls within the anti-avoidance provisions as outlined in CTM92780 and is not exempted by falling within CTM92790, a charge arises under Regulation 14 (2).

In working out the amount chargeable under Regulation 14 (2):

• consider each accounting period separately,
• calculate the hypothetical payment dates of the twelve month period that would have occurred if the company had not changed the date of the 'relevant accounting period' (defined in CTM92780) or transferred taxable profits,
• calculate interest by reference to the actual dates of payment of tax and the hypothetical dates,
• take into account accelerated as well as deferred amounts of CT,
• use the interest rate for both accelerated and deferred amounts of CT that is normally charged on CT paid late under TMA70/S87A.

See the example at CTM92810.