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Time is money: how to mitigate late payment interest in tax disputes

Jack Prytherch (Osborne Clarke) sets out the practical steps that taxpayers can take to minimise delays in their disputes with HMRC and so mitigate any additional interest charged.

Many taxpayers will have been left frustrated by extended delays when facing HMRC investigation or assessment. As recently reported in Tax Journal (25 April 2025) research suggests that HMRC investigations into UK’s largest businesses now last an average of 45 months.

Another key challenge that this presents is in relation to late payment interest. Historically the rate of late payment (simple) interest charged by HMRC tracked at 2.5% above the Bank of England base rate. In recent years base rate increases have brought late payment interest into sharper focus....

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