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HMRC internal manual

Capital Gains Manual

Migration of companies: residence: settlement of liabilities

When a company does migrate after 15 March 1988 FA88/S130 to FA88/S132 impose variousrequirements on it designed to ensure that it settles all its tax liabilities in duecourse, see CTM34100 onwards. However there is an exemption from Sections 130(1)-(6) and131(1)-(5) for companies becoming non-resident on 30 November 1993 solely by reason of theenactment of FA94/S249.