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HMRC internal manual

Company Taxation Manual

Residence: outward company migration: notice and arrangements

FA88/S130 - S132, now migrated to TMA70/S109B to S109F (see CTM34120) are intended to prevent a company migrating and leaving behind outstanding tax liabilities which would be very difficult to collect.

TMA70/S109B requires a company, before it migrates, to:

  • notify HMRC of its intention to cease to be resident, and migration time
  • provide a statement of its tax liabilities,
  • make arrangements for the settlement of these liabilities in due course, and
  • obtain HMRC’s approval of the arrangements.

A disagreement on the estimated liabilities may be referred to the First Tier Tribunal.

CTIS (Business International) is responsible for accepting the estimates and approving the arrangements. Local offices may be asked to help in checking the tax computations. The company will normally be required to provide a guarantor for outstanding tax liabilities. Guidance notes for migrating companies were issued as SP2/90 and are reproduced at CTM34195. Companies enquiring about TMA70/S109B should be referred to those notes.