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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: other issues

Time limit for application and late claims

Remember the time limit is in line with the normal due date for CT, nine months after the end of the migration accounting period. In general, late applications will be accepted only where there are reasons for the delay beyond the company’s control. There is discussion of what these might, and might not, be in SP5/01 in the context of late claims to reliefs.  (This content has been withheld because of exemptions in the Freedom of Information Act 2000)

Claims for periods before 12 March 2012

Refer these to BAI (Technical).


Review the application and make early request for any missing details, for instance place of migration, address for correspondence following migration, possible changes of agent and so forth.