Paragraph 5

Section 109E (liability of other persons for unpaid tax) is amended as follows.

After subsection (1) insert—

“(1A)

The reference in subsection (1)(b) to the time when tax becomes payable is a reference to—

(a)

in a case where an exit charge payment plan has been entered into in accordance with Schedule 3ZB in respect of the tax, the time when the tax becomes payable under the plan, and

(b)

in any other case, the time when the tax becomes payable in accordance with section 59D or 59E.”

In subsection (2), for “the time when the amount of the tax is finally determined” substitute “ the relevant time ”.

After subsection (2) insert—

“(2A)

In subsection (2) the “relevant time” means—

(a)

in a case where an exit charge payment plan has been entered into in accordance with Schedule 3ZB in respect of the tax, the later of—

(i)

the first day after the period of 12 months beginning immediately after the migration accounting period (as defined in Part 1 or 2 of Schedule 3ZB, as the case may be), and

(ii)

the date on which the tax is payable under the plan, and

(b)

in any other case, the time when the amount of the tax is finally determined.”