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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: action in HMRC offices: technical issues

All ECPP proposals received should be referred to a Grade 7 officer for advice and decision on acceptability.

The officer should bear in mind

  • the company’s eligibility - CTM34132
  • issues around migration - INTM120000 onwards
  • valuation of and comprehensiveness of assets (especially intangibles) and liabilities within the exit charge computation
  • where the realisation method (CTM34135) is proposed

    • allocation of tax to individual assets
    • expected useful life of intangibles, fixed assets, loan relationships and derivative contracts
  • where the instalment method (CTM34134) is proposed, pointers to avoidance which might require the realisation method to be used
  • pointers to the need for security, which will have regard to whether tax could be recovered from another group company or controlling director under TCGA92/S190 (see CG45970 onwards), and if considered necessary will require a reference to to BAI (Technical).