If HMRC believes the company has made a relevant payment which it has not included in a return or is dissatisfied with a return, the company is assessable to the best of an officer's judgment.

For the purpose of computing interest on unpaid tax, the IT due on such an assessment is treated as payable when it would have been due if a correct return had been made.

It may be argued that making such assessments is pointless because:

the paying company has failed to deduct IT but the recipient company has been taxed on the gross interest received, or

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