CTM92480 | Corporation Tax self-assessment (CTSA): the payment obligation: payment for surrendered tax refund
From HM Revenue & Customs · Company Taxation Manual
Any payment made between the surrendering and recipient companies in respect of a transferred tax refund is treated as having no tax consequences, that is:
it is not taken into account in computing profits or losses of either company for CT purposes, and
it is not regarded as a distribution or a charge on income.