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).