Brief

On 27/01/2025, Her Majesty's Revenue and Customs (HMRC) issued an update regarding "Pay Corporation Tax if you're a large company". Large companies with profits over £1.5 million must pay Corporation Tax electronically by instalments, except for specific exceptions, including profits under £10 million in certain conditions or total liability under £10,000.

If your company’s profits for an accounting period are at an annual rate of more than £1.5 million, you must normally pay your Corporation Tax for that period electronically and in instalments.
There are different rules you must follow if you have a profit of over £20 million.
Large companies
A large company is one whose profits for the accounting period in question are at an annual rate of more than £1.5 million but less than £20 million.
Generally ‘large’ companies must pay their Corporation Tax electronically by instalments.
Exceptions
Your company does not need to pay by instalments for an accounting period (even though its profits exceed £1.5 million) if either:

the amount of its total liability for the accounting period is less than £10,000 (or when the accounting period is less than 12 months, less than an annual rate of £10,000)
its profits for the accounting period are no more than £10 million and either:

it did not exist or did not have an accounting period at any time during the previous 12 months
its annual rate of profit was no more than £1.5 million, or its annual rate of tax liability was no more than £10,000, for any accounting period which ended in the previous 12 months

If either of these conditions apply, the company must pay its tax in full by the normal payment due date.
Accounting periods beginning before 1 April 2015 and beginning on or after 1 April 2023
If your company has associated companies for accounting periods beginning before 1 April 2015 and beginning on or after 1 April 2023, the £1.5 million and £10 million thresholds are reduced by dividing these by the number of associated companies, plus your company.
This new figure is the relevant threshold for your company.
Example — accounting period from 1 December 2023 to 30 November 2024
A company has 5 associated companies. Its profits for the 12 month accounting period ending 30 November 2024 are £300,000 and its Corporation Tax liability is £75,000. The annual adjusted threshold is:
£1.5 million divided by 6 (that is, 5 + the company itself) = £250,000.
The company is a large company for this accounting period. Even though its profits are less than £1.5 million, they exceed the adjusted annual threshold of £250,000 and its tax liability is greater than £10,000.
A company is associated with another company if:

one is under the control of the other
both are under the control of the same person or persons

Control is usually defined by reference to ownership of share capital or voting power.
A company may be an associated company no matter where it’s resident for tax purposes.
Accounting periods beginning on or after 1 April 2015 and before 1 April 2023
For accounting periods beginning on or after 1 April 2015 and before 1 April 2023, the associated companies rules were replaced by a 51% group test.
If the company has related 51% group companies, the £1.5 million and £10 million thresholds are reduced by dividing these by the number of related 51% group companies plus your company.
This new figure is the relevant threshold for your company.
Company A is a related 51% group company of company B if:

A is a 51% subsidiary of B
B is a 51% subsidiary of A
A and B are 51% subsidiaries of the same company

‘A’ is a 51% subsidiary of ‘B’ if more than 50% of its ordinary share capital is beneficially owned (directly or indirectly) by ‘B’.
Example — accounting period from 1 May 2019 to 30 April 2020
A company has 4 related 51% group companies. Its profits for the 12 month accounting period ending 30 April 2020 are £400,000 and its Corporation Tax liability is £76,000.
The annual adjusted threshold is: £1.5 million divided by 5 (that is, 4 + the company itself) = £300,000.
Although the profits for the accounting period are below £1.5 million, the profits exceed the adjusted annual threshold of £300,000.
As the tax liability also exceeds £10,000, the company is large for the accounting period.
When instalment payments need to be paid
For accounting periods of 12 months, you’ll normally pay your Corporation Tax in 4 quarterly instalments, 2 of which are due before the end of your accounting period.
Accounting periods of 12 months
If your company has a 12 month accounting period, you need to pay in 4 equal instalments due:

6 months and 13 days after the first day of the accounting period
3 months after the first instalment
3 months after the second instalment (14 days after the last day of the accounting period)
3 months and 14 days after the last day of the accounting period

This applies to accounting periods ending after 30 June 2002.
Example — accounting period from 1 January 2026 to 31 December 2026

Payment
Payment due date

First payment
14 July 2026

Second payment
14 October 2026

Third payment (due after the end of the accounting period)
14 January 2027

Final payment
14 April 2027

Accounting periods less than 12 months
If your company has an accounting period less than 12 months, your last instalment will be due 3 months and 14 days after the last day of your accounting period.
If your accounting period is longer than 3 months, the first payment will be due 6 months and 13 days after the first day of the accounting period.
If your accounting period is long enough, other payments will also be due at 3 monthly intervals after then.
Example — accounting period from 1 January 2027 to 31 August 2027

Payment
Payment due date

First payment
14 July 2027

Second payment due after the end of the accounting period
14 October 2027

Final payment
14 December 2027

Example — accounting period from 1 January 2027 to 31 March 2027
All Corporation Tax is due in a single instalment on 14 July 2027.
Work out instalment payments
Step 1: estimate your company’s total liability
To work out your instalment payments, first estimate your Corporation Tax liability for the accounting period, including any tax due on:

loans to directors and other participators in ‘close’ companies
controlled foreign companies

Then, deduct all reliefs and set-offs to arrive at your company’s total liability, as you would when working out your Corporation Tax due on your Company Tax Return.
Use this figure to work out your instalment payments.
Step 2: work out the amount of each instalment
For a 12 month accounting period, you pay your total liability in 4 equal instalments. Each instalment is a quarter of your company’s total liability.
For accounting periods of 3 months or less, make 1 single payment of your company’s total liability.
For accounting periods longer than 3 months but less than 12, all instalments except the last will be the company’s total liability divided by the number of months in the accounting period, multiplied by 3.
The last instalment will be your company’s total liability, less the payments made so far.
Example — accounting period from 1 January 2027 to 31 August 2027 and £900,000 in Corporation Tax to pay

Calculation step
Result

Company’s total liability
£900,000

Months in the accounting period
8

Company’s total liability ÷ months in the accounting period x 3
£900,000 ÷ 8 x 3 = £337,500

Smaller of company’s total liability and company’s total liability ÷ months in the accounting period x 3
£337,500

First and second instalment payments
£337,500

Third and final payment
£900,000 – (2 × £337,500) = £225,000

Step 3: revise your estimate and adjust your payments
Your estimate of your Corporation Tax liability may change as the accounting period progresses. This may even happen after your last instalment payment. You’ll need to work out each instalment payment based on the revised figure.
If you think your liability is going to be greater than your earlier estimates, you’ll need to make one or more ‘top-up’ payments to cover the shortfall in your previous instalments.
You can make additional payments at any time. You may need to pay interest if you’ve made instalment payments that turn out to be lower than your actual liability.
If you later find that you’ve paid too much (or should not have made a payment at all), you’ll normally be able to claim back your overpayment, or you can leave the overpayment with HMRC and deduct the overpayment from future instalment payments.
You might receive interest on overpayments of instalment payments and on payments made early.
Ring fence companies
If your company is liable to Corporation Tax and supplementary charge on profits from ring fence activities (UK Continental Shelf oil-related activities that under UK law constitute a separate trade), you’ll pay any Corporation Tax due on non-ring fence profits in instalments using the normal rules.
For accounting periods beginning on or after 1 April 2019, if your profits exceed £20 million, you will pay any tax due on non-ring fence profits by instalments using the rules for very large companies. Find out more about the rules you must follow if you have a profit of over £20 million.
You’ll also need to pay the Corporation Tax and supplementary charge on your ring fence profits in a maximum of 3 equal instalments due:

6 months and 13 days after the first day of the accounting period
3 months after the first instalment
14 days after the last day of the accounting period

This applies to accounting periods ending after 30 June 2005.
For 12 month accounting periods ending after 30 June 2005 but before 1 July 2006, instalments are 25%, 25% and 50% of the ring fence liability.
Example — accounting period from 1 January 2027 to 31 December 2027

Payment
Payment due date

First payments of both ring fence tax and other Corporation Tax
14 July 2027

Second payments of both ring fence tax and other Corporation Tax
14 October 2027

Third (final) payment of ring fence tax, and third payment of other Corporation Tax
14 January 2028

Final payment of other Corporation Tax
14 April 2028

Example — accounting period from 1 January 2027 to 31 May 2027

Payment
Payment due date

All ring fence tax is due on this date
14 June 2027

First payment for other Corporation Tax
14 July 2027

Second (final) payment for other Corporation Tax
14 September 2027

The date the third instalment would be due (14 June 2027) falls before any of the other payment due dates, then all the ring fence tax is due is payable on 14 June 2027.
Work out instalment payments for ring fence companies
If your company is liable for Corporation Tax and supplementary charge on profits from ring fence activities, work out instalments for Corporation Tax due on non-ring fence profits using the normal rules.
You’ll also need to work out your instalments for the Corporation Tax and supplementary charge on your ring fence profits.
Step 1: work out your ring fence amount
Estimate the ring fence Corporation Tax and supplementary charge payable for the accounting period.
Step 2: work out your instalment payments
For a 12 month accounting period, you pay your total liability in 3 equal instalments, each one a third of the ring fence amount.
For accounting periods of 4 months or less, you make 1 single payment of your total liability.
For accounting periods longer than 4 months but less than 12, your payments are the smaller of the balance of the ring fence amount unpaid, or the ring fence amount divided by the number of months in the accounting period, multiplied by 4.
These rules apply for accounting periods ending on or after 1 July 2006.
If you want to check calculations for accounting periods ending after 30 June 2005 but before 1 July 2006, use the following:
Ring fence amount ÷ the number of months in the accounting period for shorter periods x 3.
Step 3: revise your estimate and adjust your payments
Your estimate of your Corporation Tax liability may change as the accounting period progresses. This may even happen after your last instalment payment. You’ll need to work out your instalment payments based on the revised figure.
If you think your liability is going to be greater than your earlier estimates, you’ll need to make one or more ‘top-up’ payments to cover the shortfall in your previous instalments.
You can make additional payments at any time. You may need to pay interest if you’ve made instalment payments that turn out to be lower than your actual liability.
If you later find that you’ve paid too much (or should not have made a payment at all), you’ll normally be able to claim back your overpayment, or you can leave the overpayment with HMRC and deduct the overpayment from future instalment payments. You might receive interest on overpayments of instalment payments and on payments made early.
Groups of companies
Group companies can choose to offset an amount overpaid by one company against an amount unpaid by another company in the group.
HMRC also offers Group Payment Arrangements, which allow groups to make instalment payments on a group-wide basis. You can nominate one company in the group to pay the instalments on behalf of the group, rather than company by company.
Make an instalment payment
You must make all Corporation Tax and related payments electronically.
Related payments include interest charged on overdue Corporation Tax and penalties for not filing your Company Tax Return on time.
Pay your instalment payments electronically online using:

a payment through your online bank account
Direct Debit
debit card
company credit card
your own bank or building society’s internet banking service

Pay electronically (but not online) using:

Bacs Direct Credit
your own bank or building society’s telephone banking service
CHAPS
Bank Giro

Interest and instalment payments
Interest charged by HMRC
HMRC charges interest on late or underpaid instalments. If you need to pay this interest, it’s tax deductible for Corporation Tax purposes.
To distinguish this from interest on normal late payments, HMRC calls this ‘debit interest’.
This interest is only worked out and charged when you submit your Company Tax Return.
Interest paid to you
HMRC will pay your company interest if:

you make instalment payments that turn out to be unnecessary
you pay them early
your payment is too high

Any interest paid will be worked out from the later of the first instalment date or when an overpayment occurs.
The interest paid by HMRC is taxable for Corporation Tax purposes. This interest is only worked out and charged retrospectively, once the liability for the period is established, normally when you submit your Company Tax Return.
The rate for this interest is different from the rate of interest charged on late payments and underpayments. HMRC calls this interest ‘credit interest’.
Example — no ring fence liability and an accounting period from 1 January to 31 December
The company reviews the estimate of its final liability at regular intervals and, when appropriate, adjusts its instalment payments (or, if necessary, makes top-up payments) to minimise any interest charge. It sends a Company Tax Return showing a final tax liability of £120 million.

Company’s estimate of its liability
Payments made based on estimated figures (with date payment made)
Actual liability based on final liability
Date due

£80 million
£20 million (14 July)
£30 million (instalment payment 1)
14 July

£110 million
£35 million (14 October)
£30 million (instalment payment 2)
14 October

£130 million
£10 million (top-up payment) (1 November)

£140 million
£40 million (14 January)
£30 million (instalment payment 3)
14 January

£120 million
£15 million (14 April)
£30 million (instalment payment 4)
14 April

In this example, interest is due as follows:

Dates
Total paid to date
Actual liability to date
Details of interest due

14 July to 13 October
£20 million
£30 million
Debit interest due on £10 million from 14 July to 13 October

14 October to 31 October
£55 million
£60 million
Debit interest due on £5 million from 14 October to 31 October

1 November to 13 January
£65 million
£60 million
Credit interest due on £5 million from 1 November to 31 January

14 January to 13 April
£105 million
£90 million
Credit interest due on £15 million from 14 January to 13 April

14 April
£120 million
£120 million
No further interest will be charged or credited

Penalties on instalment payments
A penalty may be charged if you deliberately:

fail to make instalment payments
make instalment payments that are too small

Find out more about Corporation Tax penalties.
Repayment claims
If, following a review at the next instalment date of the latest management accounts and forecasts, you find that your Corporation Tax liability will be less than expected, you can make a claim for repayment of some or all of your instalment payments.
Claims must be made to an officer of HMRC and must state both:

the amount that you consider should be repaid
your grounds for believing that, because of a change in circumstances since the payment or payments were made, the:

amount of your total liability for the period is likely to be less than previously worked out
cumulative payments are more than the revised liability

In some circumstances, you may make a repayment claim when your revised liability includes anticipated losses from your current accounting period that has not yet ended.
This may occur if you have sustained significant losses. You will need to provide supporting evidence to verify the losses and support your claim for repayment. Find out more about repayment claims in the HMRC company taxation manual.

Highlights content goes here...

Purpose

The purpose of this document is to outline the rules and procedures for paying Corporation Tax by instalments, particularly for large companies with profits exceeding £1.5 million but less than £20 million. The guidelines also cover repayment claims, ring fence companies, and group payment arrangements.

Effects on Industry

The introduction of instalment payments for large companies will have significant effects on the industry. Companies with profits above £1.5 million will need to pay their Corporation Tax in four quarterly instalments, which may require them to adjust their financial planning and cash flow management. This may lead to increased financial burdens for some companies, particularly those with high tax liabilities.

On the other hand, this change may also encourage larger companies to review their financial strategies and consider implementing more efficient tax planning measures. Additionally, the requirement for instalment payments may prompt companies to seek professional advice from accountants or tax experts to ensure they are meeting their tax obligations.

Relevant Stakeholders

The following stakeholders will be affected by these guidelines:

  1. Large Companies: Those with profits exceeding £1.5 million but less than £20 million will need to pay their Corporation Tax in instalments.
  2. Accountants and Tax Experts: Professionals who advise companies on tax planning and financial matters may see an increase in demand for their services as companies navigate the new rules.
  3. HMRC: The UK’s tax authority will be responsible for enforcing these guidelines and ensuring that large companies meet their tax obligations.

Next Steps

Companies with profits above £1.5 million but less than £20 million will need to:

  1. Review their financial plans: Adjust their cash flow management and financial planning to accommodate the new instalment payment schedule.
  2. Consult with accountants or tax experts: Seek professional advice on how to meet their tax obligations under these new rules.
  3. Make instalment payments: Pay their Corporation Tax in four quarterly instalments, as required.

Any Other Relevant Information

The guidelines also cover repayment claims and ring fence companies. Companies may be able to claim a refund of excess instalment payments if their revised liability is lower than expected. Additionally, ring fence companies will need to pay their tax on profits from these activities separately, with a maximum of three instalments due.

It’s worth noting that HMRC offers Group Payment Arrangements, which allow groups of companies to make instalment payments on a group-wide basis, rather than company by company. This may provide relief for some companies and help them manage their tax obligations more efficiently.

Her Majesty’s Revenue and Customs (HMRC)

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