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HMRC internal manual

Company Taxation Manual

Residence: outward company or permanent establishment migration: liabilities arising: deferral of exit charges: exit charge payment plan: instalment method

The instalment method is the straightforward standard method, and simplifies matters greatly if it can be adopted as the exclusive method.

The ECPP tax is spread into six equal annual instalments. It may not be used where the deferral of payment of tax is a main purpose, or one of the main purposes, of the arrangements that include the change of residence of the company or (in the case of a migrating permanent establishment) the transfer of the assets and liabilities that are subject to exit charges.

Deferral runs for the full six years unless the company

  • decides to pay the balance of any unpaid tax and interest, or
  • one of the relevant events mentioned at CTM34133 occurs.