# The Corporation Tax Act 2010 (Part 8C) (Amendment) Regulations 2025, Note: Explanatory note


(This note is not part of the Regulations)
The Regulations amend Part 8C of the Corporation Tax Act 2010 (“CTA 2010”) which was inserted into the CTA 2010 by section 38(3) of Finance (No. 2) Act 2015. Part 8C applies a corporation tax rate of 45% to payments of restitution interest made by the Commissioners for His Majesty’s Revenue and Customs (“HMRC”).
Regulations 3 to 5 provide that Part 8C of the CTA 2010 does not apply to awards of simple interest that are at a rate equivalent to or lower than a statutory rate (which is defined by section 357YU(2) of the CTA 2010 as a rate equal to a rate specified for purposes relating to taxation in a provision in or made under an Act of Parliament).
Regulation 6 provides that an assessment of tax chargeable on restitution interest made under Part 8C of the CTA 2010 can be made at any time before the end of the period of 2 years after the end of the accounting period in which Condition B in section 357YC is met or the end of any period within which the assessment may otherwise be made under any other provision of the Taxes Acts, whichever is later. This provides that assessments can be made for adjustments made under sections 357YE and 357YH of the CTA 2010 where restitution interest is brought into account at a time before a court has made a final determination or before HMRC has entered into a final settlement to pay restitution interest.
A Tax Information and Impact Note covering this instrument will be published on the website at https://www.gov.uk/government/collections/tax-information-and-impact-notes-tiins.

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Source: https://www.legislation.gov.uk/uksi/2025/1253/note (the official version)
Page: https://openlegislation.uk/corporation-tax-act-2010-part-8c-amendment-regulations-2025/note
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.