CFM99000 | Interest restriction: administration: penalties: penalties for failure to deliver an interest restriction return

Interest restriction: Administration: Penalties: Penalties for failure to deliver an interest restriction return

This page of guidance applies for periods of account ending on or after 31 March 2026 unless otherwise stated. See section at the bottom for the rules as they apply for periods ending before that date.

TIOPA10/SCH7A/PARA29

A reporting company becomes liable to a penalty under TIOPA10/SCH7A/PARA29 if:

• it delivers a return after the filing date as specified by PARA7,

• it fails to deliver a return by the filing date following the appointment of a reporting company or replacement company by HMRC, or

• it fails to submit a revised return by the deadline as required by PARA8(4).

That filing date for a PARA7 return is usually 12 months after the end of the worldwide group’s period of account or, if later, 3 months after the appointment of the reporting company. See CFM98520 for full details and possible exceptions to the normal filing dates.

The filing date for a revised return is set out at PARA8(5). See also CFM98530.

A late filing penalty for a revised return only applies for periods of accounts beginning on or after 1 April 2023. For earlier periods no late filing penalty is chargeable for failure to file a revised return

The penalty is £500 if the return is delivered within 3 months after the filing date, or £1,000 thereafter.

The penalty is levied by an assessment by an officer of Revenue and Customs, notified to the company, within 12 months of the date that the return is received by HMRC. It is payable within 30 days of that assessment.

No penalty is chargeable where the reporting company has a ‘reasonable excuse’ for the failure, and the return is delivered without unreasonable delay when the excuse ceases (PARA29A). This is in line with the approach taken for late filing under Corporation Tax Self-Assessment. For examples of what HMRC will consider as being a ‘reasonable excuse’, please see CTM94150.

The company has 30 days within which it may give notice of appeal against the penalty.

Periods of account ending before 31 March 2026

For periods of account ending before 31 March 2026, a reporting company was required to submit an interest restriction return for every period for which it is reporting company. Failure to submit a return for any such period gave rise to a penalty under PARA29. For periods ending before 31 March 2026 HMRC had 12 months from the filing date to assess the penalty.