Section 59F: Arrangements for paying tax on behalf of group members, Taxes Management Act 1970

An officer of Revenue and Customs may enter into arrangements for the specified purpose with some or all of the members of a group.

For the purposes of subsection (1), arrangements entered into with some or all of the members of a group are for "the specified purpose" if they are arrangements for one of those members to discharge any liability of each of those members to pay corporation tax for the accounting periods to which the arrangements relate.

For the purposes of this section, a company and all its 51% subsidiaries form a group and, if any of those subsidiaries has 51% subsidiaries, the group includes them and their 51% subsidiaries, and so on.

Arrangements entered into under subsection (1)—

may make provision in relation to cases where companies become or cease to be members of a group,

may make provision in relation to the discharge of liability to pay interest or penalties,

may make provision in relation to the discharge of liability to pay any amount within subsection (6),

may make provision for or in connection with the termination of the arrangements, and

may make such supplementary, incidental, consequential or transitional provision as is necessary for the purposes of the arrangements.

Arrangements entered into under subsection (1)—

do not affect the liability to corporation tax, or to pay corporation tax, of any company to which the arrangements relate, and

do not affect any other liability under the Tax Acts of any company to which the arrangements relate.

The following amounts are within this subsection—

an amount due from a company under section 455 or 464A of CTA 2010 (charge to tax in case of loan or benefit to participator in close company) as if it were an amount of corporation tax chargeable on the company, and

a sum charged on a company at step 5 in section 371BC(1) of TIOPA 2010 (controlled foreign companies) as if it were an amount of corporation tax, ...

the bank levy where treated as an amount of corporation tax chargeable on a company by paragraph 50 or 51 of Schedule 19 to the Finance Act 2011 (the bank levy), ...

to any sum chargeable on a company under section 33 of FA 2022 (residential property developer tax) as if it were an amount of corporation tax chargeable on the company, and

to any sum chargeable on a company under section 1 of the Energy (Oil and Gas) Profits Levy Act 2022 as if it were an amount of corporation tax chargeable on the company.

Section 59F: Arrangements for paying tax on behalf of group members

Discussed in

About this text