
1 
These Regulations may be cited as the Corporation Tax Act 2010 (Part 8C) (Amendment) Regulations 2025 and come into force on 15th January 2026.
2 
Part 8C of the Corporation Tax Act 2010 is amended in accordance with regulations 3 to 6.
3 
In section 357YC (meaning of “restitution interest”)—
(a) in subsection (4), after “simple interest at a” insert—“
rate equivalent to or lower than a
”, and
(b) in subsection (5), after “simple interest at a” insert—“
rate equivalent to or lower than a
”.
4 
In section 357YD (further provision about amounts included, or not included, in “restitution interest”)—
(a) in subsection (1), in paragraph (b), after “simple interest at a” insert—“
rate equivalent to or lower than a
”, and
(b) in subsection (2), after “simple interest at a” insert—“
rate equivalent to or lower than a
”.
5 
In section 357YO (duty to deduct tax from payments of restitution interest), in subsection (4), after “simple interest at a” insert—“
rate equivalent to or lower than a
”.
6 
In section 357YQ (assessment of tax chargeable on restitution interest), after subsection (1) insert—“
(1A) An assessment under this section may be made at any time before the later of—
(a) the end of the period of 2 years after the end of the accounting period in which Condition B in section 357YC is met, and
(b) the end of any period within which the assessment may otherwise be made under any other provision of the Taxes Acts (within the meaning of section 118(1) of TMA 1970).”.
Gen Kitchen
Stephen Morgan
Two of the Lords Commissioners of His Majesty's Treasury
at 1.50 p.m. on 1st December 2025