Prospective
11U.K.In Part 2 (special provision as to repayment interest start date), after paragraph 9A insert—
9B(1)This paragraph applies to—
(a)a repayment of income tax which falls to be made in respect of a payment received by a company in an accounting period, and
(b)a payment of the whole or part of the tax credit comprised in any franked investment income received by a company in an accounting period.
(2)In the case of a repayment or payment to which this paragraph applies, the repayment interest start date is the day after the end of the accounting period in which the payment mentioned in sub-paragraph (1)(a) or the franked investment income mentioned in sub-paragraph (1)(b) was received by the company.
9C(1)In the case of a repayment of tax made on a claim under section 458(3) of CTA 2010 (relief on repayment of loan made by close company to participator), the repayment interest start date is the later of dates A and B.
(2)Date A is—
(a)where the loan repayment date is on or after the tax due date, the date 9 months after the end of the accounting period in which the loan repayment date falls, and
(b)in any other case, the date 9 months after the end of the accounting period in which the loan date falls.
(3)Date B is the date on which the tax which is to be repaid was paid to HMRC.
(4)In this paragraph, in relation to a claim under section 458(3) of CTA 2010—
“the loan date” is the date on which the loan or advance giving rise to the charge to tax under section 455 of that Act is made;
“the tax due date” is the date on which tax under that section becomes due (in accordance with subsection (3) of that section) in relation to that loan or advance;
“the loan repayment date” is the date on which the whole or any part of the loan or advance is repaid, released or written off.”