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HMRC internal manual

Company Taxation Manual

Residence: outward company migration: penalties for non- compliance

If a company ceases to be resident without satisfying the requirement to give notice and to make arrangements, it is liable under TMA70/S109C to a penalty up to the amount of its outstanding liabilities at the date of migration. The directors of the company and of its controlling companies and the controlling companies themselves may also each be liable to a similar penalty.

Report to CTIS (Business International) any case where a company has apparently ceased to be resident but has not given notice under TMA70/S109B. See ‘Technical Help’ on the left bar.