CTM34160 - Residence: outward company migration: notice and arrangements

FA88/S130 - S132 are intended to prevent a company migrating and leaving behind outstanding tax liabilities which would be very difficult to collect.

Section 130 requires a company, before it migrates, to:

• notify the Board of its intention to cease to be resident,

and

• provide a statement of its tax liabilities,

and

• make arrangements for the settlement of these liabilities in due course,

and

• obtain the Board's approval of the arrangements.

A disagreement on the estimated liabilities may be referred to the Special Commissioners.

CT&VAT, International CT, is responsible for accepting the estimates and approving the arrangements. Districts may be asked to help in checking the tax computations. The company will normally be required to provide a guarantor for outstanding tax liabilities. Guidance notes for migrating companies were issued as SP2/90 and are reproduced at CTM34195. Companies enquiring about Section 130 should be referred to those notes.