»Ê¹ÚÌåÓýapp

This subject is presented as follows.

General
Eligible companies
Relevant APs
Administration and application formsÌý

General

»Ê¹ÚÌåÓýapp statutory basis for Group Payment Arrangements, introduced at the same time asÌýCorporation Tax Self AssessmentÌý(CTSA), is in Section 36 Finance Act 1998. HM Revenue and Customs are empowered to offer companies in a group the facility to have one company pay tax on behalf of all of them.

»Ê¹ÚÌåÓýapp aim of Group Payment Arrangements is to help groups containing large companies manage any uncertainty over the amount of the individual companiesâ€� tax liabilities in the period between:

• the liabilities falling due
• delivery of the individual companiesâ€� tax returns

»Ê¹ÚÌåÓýapp arrangements mean that groups still have to pay the right amount of CT at the right time, but in estimating what is due to be paid they can forecast for the participating companies as a whole, rather than for each individual company and pay on that basis, rather than having to divide payments between the companies in the group.

»Ê¹ÚÌåÓýapp arrangements mitigate the effect on a group of the differential interest rates on overpaid and underpaid tax up until the payments for a group payment period have been allocated out of an arrangement to the individual participating companies. »Ê¹ÚÌåÓýappreafter, any movements of monies between participating companies are subject to the normal rules, for example S963 Corporation Tax Act (CTA) 2010 claims (formerly S102) or Reg 9.

For full details of the working arrangements for group payments, see COM96000 onwards.

Eligible companies

Companies eligible to enter into the arrangements are:

• parent companies and their 51 percent subsidiariesÌý(for APs ending on or before 31 March 2023)/associated companies (for APs ending on or after 1 April 2023)
• the 51 percent subsidiaries of those subsidiaries, and so onÌý(for APs ending on or before 31 March 2023)/associated companies (for APs ending on or after 1 April 2023)

Not all companies in the group need be resident in the UK, but the company nominated to pay on behalf of the participating companies (the nominated company) must be resident or based in the UK. UK subsidiaries of overseas parent companies and UK branches of non-resident companies can come within an arrangement.ÌýFor further information see CTM97420 onwards.

Not all members of the group need be covered by the Group Payment Arrangement and a group may apply to set up more than one arrangement for different subsets of companies in the group. »Ê¹ÚÌåÓýapp participating companies have to make up accounts to the same date as the nominated company.

Only companies that have delivered returns and paid tax due in respect of their last but one Accounting Period (AP), and new or newly activated companies, are eligible to be covered by an arrangement.

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Relevant APs

»Ê¹ÚÌåÓýapp arrangement relates to periods of account of the nominated company. »Ê¹ÚÌåÓýapp periods cannot be longer than 12 months.

Each period must be an Accounting Period (AP) of each of the participating companies.

A company that is newly formed, newly activated or newly acquired by the group will, by agreement, be able to be covered by the arrangement, provided it aligns its accounting date with that of the nominated company. Such a company cannot be covered by the arrangement in respect of an AP that began before the period of account covered by the arrangement.

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Administration and application forms

Group Payment Arrangements are set up and administered by Group Payment Team at Accounts Office.

Groups wanting further information or an application form must contact the Group Payment Team or look on the HMRC website.

»Ê¹ÚÌåÓýapp address and telephone number of the Group Payment Team is:

Group Payment Arrangement Team (GPAT)
HM Revenue and Customs
BX9 1GE

Telephone:Ìý03000 583 947

See COM30021 for legislation applying to this subject.