Section 109B Provisions for securing payment by company of outstanding taxF1

Each of conditions A to D must be met before a company ceases to be resident in the United KingdomF2, subject to subsection (5A).

Condition A is that the company gives to the Commissioners for Her Majesty's Revenue and Customs notice of its intention to cease to be resident in the United Kingdom.

Condition B is that the notice specifies the time (“the migration time”) when the company intends to cease to be resident in the United Kingdom.

Condition C is that the company gives to the Commissioners—

Condition D is that—

Condition D does not apply to the extent that payment of the tax is to be secured by the company entering into a CT exit charge payment plan in accordance with Schedule 3ZB.

If any question arises as to the amount which, for the purposes of subsection (5), should be regarded as the amount of tax which is or will be payable by the company in respect of periods beginning before the migration time, that question is to be referred to the tribunal.

A decision of the tribunal under subsection (6) is final, despite sections 11 and 13 of the TCEA 2007 (appeals from tribunal decisions).

If any information furnished by the company for the purpose of securing the Commissioners' approval under subsection (5) does not fully and accurately disclose all facts and considerations material for the Commissioners' decision under that subsection, any resulting approval is void.