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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: on and following acceptance of claim

The responsible officer should write to the company or agent confirming acceptance of the application and detailing any amendments that might have been necessary following enquiries. If the realisation basis applies, the letter should record the reporting requirements (CTM34136).

Any Exit Charge Payment Plan (ECPP) tax must be informally stood over on COTAX, with an explanation mentioning ECPP. A review date signal should be set, in advance of the first payment instalment becoming due, and annually following. See COM10121, step18.

At annual reviews

  • for instalment only cases, release for collection the amount of tax falling due on each anniversary not yet paid
  • for other cases, which will involve realisation method in some degree, ensure the company’s report of realisations has been received, and release for collection the amount of tax attributable to those realisations.

If the report has not been received, first write to the company or agent known to be acting asking for the report. If there is no satisfactory response, consider taking advice on making use of the Mutual Assistance Directive (in the EU) or appropriate Double Tax Convention - see INTM156010 onwards. In the last resort, release the tax for collection.