RPDT40200 - Commencement and transitional provisions: transitional rule for QIPs
Where a company’s CT liability is paid in quarterly instalments, its payments in respect of RPDT will be due on the same dates. For accounting periods that straddle the RPDT commencement date of 1 April 2022 (see RPDT40100), some of the instalment dates for that accounting period may fall before that commencement date. FA22/S51(4) prevents any obligation to pay RPDT within those pre-commencement instalments from arising. Instead, under FA22/S51(5), any quarterly instalment payments that would have become due and payable before the commencement date are treated as being due and payable on the first instalment date after the commencement date.
Example
A Ltd is an RP developer whose 12-month accounting period ends on 31 December 2022. It is within the quarterly instalment payment regime for very large companies. Its CT payments are therefore due on:
- 14 March 2022
- 14 June 2022
- 14 September 2022
- 14 December 2022
The first payment date falls prior to the commencement of RPDT, so no RPDT needed to be paid at that time. The first post-commencement instalment on 14 June 2022 should then include the RPDT which would otherwise have been payable on 14 March 2022 and the RPDT that is payable on 14 June 2022. Payments on the subsequent dates will be calculated in the normal way as for CT.
RPDT01100 contains a general introduction to RPDT and a list of abbreviations used.