CTM34190 | Residence: outward company migration: recovery of tax from other persons
From HM Revenue & Customs · Company Taxation Manual
If tax due by a company which has migrated is not paid within six months from the time it was payable, it may be recovered under , but only on instruction from BAI (Base Protection). Unpaid tax may be recovered from either
any company which has been a member of the same group as the migrating company at any time in the period beginning twelve months before migration (but not earlier than 15 March 1988), or
any controlling director of the migrating company or of a company which controls it (within the same period).
A group is defined in terms of with the substitution of 51 per cent subsidiary for 75 per cent subsidiary. Control is defined as at .
The provisions of may be used to recover tax whether or not arrangements have been made under or penalties have been incurred.