CTM34137 | Residence: outward company or permanent establishment migration: liabilities arising: deferral of exit charges: exit charge payment plan: action in HMRC offices: technical issues
From HM Revenue & Customs · Company Taxation Manual
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’s eligibility, ,
issues around migration, onwards,
valuation of and comprehensiveness of assets (especially intangibles) and liabilities within the exit charge computation,
where the realisation method, , 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, , 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 , see onwards, and if considered necessary will require a reference to to BAI (Technical).