CTM34137 - 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鈥檚 eligibility, CTM34132,
  • issues around migration, 听辞苍飞补谤诲蝉,
  • valuation of and comprehensiveness of assets (especially intangibles) and liabilities within the exit charge computation,
  • where the realisation method,聽CTM34135, is proposed
    • allocation of tax to individual assets, and
    • expected useful life of intangibles, fixed assets, loan relationships and derivative contracts,
  • where the instalment method,聽CTM34134, is proposed pointers to avoidance which might require the realisation method to be used instead, and
  • 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聽if聽considered necessary will require a reference to to BAI (Technical).