CTM94080 - CTSA: penalties for late returns: Amount of tax unpaid: Surrender of refund
Under CTA10/S963 a group company may surrender a refund of tax to another group company.
To calculate tax 바카라 사이트˜unpaid바카라 사이트™ for the purposes of a tax-related penalty you treat the receiving company as having paid the amount of the refund on the day the companies jointly gave valid notice of the surrender. You do not use the 바카라 사이트˜relevant date바카라 사이트™, which is the date on which the surrender is effective for interest purposes (CTA10/S964(6)).