CTM94080 - CTSA: penalties for late returns: Amount of tax unpaid: Surrender of refund

Under CTA10/S963 a group company may surrender a refund of tax to another group company.

To calculate tax ‘unpaid’ for the purposes of a tax-related penalty you treat the receiving company as having paid the amount of the refund on the day the companies jointly gave valid notice of the surrender. You do not use the ‘relevant date’, which is the date on which the surrender is effective for interest purposes (CTA10/S964(6)).