SolvedCH143040 | Interest: Late payment interest: Special provisions: Special provisions for start dates: Recovery of dividend tax credits or interest on that payment
From HM Revenue & Customs · Compliance Handbook
You must check whether, and from which date, the FA 2009 interest rules apply to the tax or duty you are dealing with. See CH140160 for full details.
A special provision changes the general rule, see CH141120, and applies where tax credits attached to a company dividend distribution have been paid or set off, in accordance with section 1109 CTA 2010, but are later found not to be due or are excessive. We will correct the tax position by one or more assessments under section 1110 CTA 2010. Such an assessment may also recover repayment interest paid to a company in connection with the incorrect tax credit.
Although payment of the section 1110 CTA 2010 assessment is, by virtue of section 1111(2) CTA 2010, due within 14 days after date of issue, late payment interest starts on the date when the tax credit or repayment interest was paid to the person.