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CTM98245 | CTSA: Loans to participators: Repayment interest

From HM Revenue & Customs · Company Taxation Manual

ICTA88/S826 (4)

The amount of repayment interest due under ICTA88/S826 (4) because of a claim under CTA10/S458 depends on when the repayment, release or write-off of the loan takes place.

  • Where the repayment, release or write-off takes place earlier than nine months and one day after the end of the accounting period in which the loan was made, repayment interest will be due from the later of:

    • nine months after the end of that accounting period, and

    • the date on which the tax to be repaid was paid.

  • Where the repayment, release or write off takes place more than nine months after the end of the accounting period in which the loan was made, repayment interest will be due from the later of:

    • nine months after the end of the accounting period in which the repayment, release or write-off takes place, and

    • the date on which the tax to be repaid was paid.