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’s eligibility, CTM34132,

• issues around migration, INTM120000 onwards,

• valuation of and comprehensiveness of assets (especially intangibles) and liabilities within the exit charge computation,

• where the realisation method, 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, 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 if considered necessary will require a reference to to BAI (Technical).