The Regulations amend Part 8C of the Corporation Tax Act 2010 (c. 4) (“CTA 2010”) which was inserted into the CTA 2010 by section 38(3) of Finance (No. 2) Act 2015 (c. 33). Part 8C applies a corporation tax rate of 45% to payments of restitution interest made by the Commissioners for Her Majesty’s Revenue and Customs (“HMRC”).