{
  "url": "https://openlegislation.uk/taxes-interest-rate-amendment-regulations-2026/regulation-2",
  "json_url": "https://openlegislation.uk/taxes-interest-rate-amendment-regulations-2026/regulation-2.json",
  "legislation": "uksi/2026/347",
  "legislation_title": "The Taxes (Interest Rate) (Amendment) Regulations 2026",
  "legislation_url": "https://openlegislation.uk/taxes-interest-rate-amendment-regulations-2026",
  "path": "regulation/2",
  "kind": "regulation",
  "number": "2",
  "heading": "Amendment of the Taxes (Interest Rate) Regulations 1989",
  "text": "(1) The Taxes (Interest Rate) Regulations 1989 are amended as follows.\n(2) After regulation 3ZE, insert—\n“Applicable rate of interest on unpaid multinational top-up tax and domestic top-up tax\n3ZF (1) For the purposes of paragraph 33 of Schedule 14 to the Finance (No. 2) Act 2023, with respect to unpaid multinational top-up tax and domestic top-up tax, the rate applicable under section 178 shall, subject to paragraph (2), be 7.75% per annum.\n(2) Where on a reference date after 17th April 2026 the reference rate found on that date differs from the established rate, the rate applicable under section 178 for the purposes mentioned in paragraph (1) shall, on and after the next operative date, be the percentage per annum found by applying the formula specified in paragraph (3).\n(3) The formula specified in this paragraph is—\nR R + 4 , where RR is the reference rate referred to in paragraph (2).\nApplicable rate of interest on overpaid multinational top-up tax and domestic top-up tax\n3ZG (1) For the purposes of paragraph 33A of Schedule 14 to the Finance Act (No. 2) 2023, with respect to overpaid multinational top-up tax and domestic top-up tax, the rate applicable under section 178 shall, subject to paragraph (2), be 2.75% per annum.\n(2) Where on a reference date after 17th April 2026 the reference rate found on that date differs from the established rate, the rate applicable under section 178 for the purposes mentioned in paragraph (1) shall, on and after the next operative date, be the higher of—\n(a) 0.5% per annum, and\n(b) the percentage per annum found by applying the formula specified in paragraph (3).\n(3) The formula specified in this paragraph is—\nR R - 1 , where RR is the reference rate referred to in paragraph (2).”.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "footnote",
      "label": "f1",
      "text": "S.I. 1989/1297; relevant amending instruments are S.I. 2008/3234, 2009/2032."
    },
    {
      "type": "footnote",
      "label": "f2",
      "text": "2023 c. 30."
    },
    {
      "type": "footnote",
      "label": "f3",
      "text": "Multinational top-up tax is defined in section 121 of the Finance (No. 2) Act 2023."
    },
    {
      "type": "footnote",
      "label": "f4",
      "text": "Domestic top-up tax is defined in section 265 of the Finance (No. 2) Act 2023. Paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023 applies paragraph 33 of Schedule 14 to domestic top-up tax."
    },
    {
      "type": "footnote",
      "label": "f5",
      "text": "Paragraph 33A was inserted into Schedule 14 to the Finance (No. 2) Act 2023 by paragraph 37(3) of Schedule 12 to the Finance Act 2024."
    },
    {
      "type": "footnote",
      "label": "f6",
      "text": "Paragraph 4 of Schedule 18 to the Finance (No. 2) Act 2023 applies paragraph 33A of Schedule 14 to the Finance (No. 2) Act 2023 to domestic top-up tax."
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2026/347/regulation/2",
    "retrieved_at": "2026-10-28T21:03:29.780940+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}