#2026/552UK order starts interest rules for tax avoidance penalty payments
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This order makes late-payment interest and HMRC repayment interest apply to certain penalties linked to non-disclosure and promotion of tax avoidance schemes from 21 May 2026. Businesses, tax advisers, promoters, and others facing these penalties may now owe interest if they pay late. If HMRC has to repay an amount, repayment interest can also apply. The order mainly switches on rules that were already planned, rather than creating a new penalty regime.
AI-generated summary. May contain errors. Refer to official sources for legal decisions.
Key Changes
- Applies late-payment interest to specified tax avoidance-related penalties from 21 May 2026
- Applies HMRC repayment interest where HMRC must repay amounts connected to those penalties
- Covers penalties under the Finance Act 2004 and Finance Act 2026 for disclosure failures, notices, inaccurate information, and related conduct
Obligations
What this law requires
From 21 May 2026, persons liable for penalties under Finance Act 2004 sections 315 or 315A must pay any sums due to HMRC on time, because late payment interest under Finance Act 2009 section 101 applies to those penalties if paid late.
From 21 May 2026, persons liable for civil or related penalties under Finance Act 2026 sections 162, 171, 194, 195, 196, 197, 198, or 210 must pay any sums due to HMRC on time, because late payment interest under Finance Act 2009 section 101 applies to those penalties if paid late.