Corporation Tax Act 2010 section 710

Recovery of unpaid corporation tax for accounting period beginning before change

Section 710 allows HMRC to recover unpaid corporation tax from persons linked to a company whose ownership has changed, where the tax relates to an accounting period beginning before that change.

• Where a company changes ownership and corporation tax assessed for a pre-change accounting period remains unpaid more than six months after assessment, HMRC may pursue recovery from linked persons, provided certain conditions about the company's trade or business are also met.
• A person linked to the company may be assessed and charged an amount of corporation tax up to the amount that remains unpaid — this is a discretionary power, not an obligation on HMRC.
• Any such assessment is made in the name of the company itself, not in the name of the linked person being charged.
• The assessment is not out of time provided it is made within three years of the date on which the company's corporation tax liability for the relevant accounting period is finally determined.

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