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Interest on late paid corporation tax: tax relief on accrual

Question:

Can you have corporation tax relief on accrued HMRC interest, or does it have to be physically paid? 

Arthur Weller replies:  

Interest is charged on overdue corporation tax and allowed on overpaid corporation tax. The interest is brought into account as non-trading interest under the loan relationships provisions in computing profits chargeable to corporation tax. See HMRC’s Company Taxation manual at CTM92190. As such, it is usually allowable when accrued ( see here).  

Can you have corporation tax relief on accrued HMRC interest, or does it have to be physically paid? 

Arthur Weller replies:  

Interest is charged on overdue corporation tax and allowed on

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This question was first printed in Business Tax Insider in September 2021.