Taxes Management Act 1970 Schedule 3ZC paragraph 11

All of outstanding balance attributable to particular qualifying transaction due

Paragraph 11 of Schedule 3ZC deals with what happens when a significant event โ€” known as a trigger event โ€” occurs during the instalment period in relation to a qualifying transaction covered by a CT payment plan, requiring the full outstanding balance of deferred tax attributable to that transaction to become due immediately.

  • A trigger event causes the entire remaining deferred tax attributable to a specific qualifying transaction to become payable during the instalment period, provided no trigger event has previously occurred for that transaction
  • Trigger events include the transferee leaving the EEA without moving to another EEA state, the company and transferee ceasing to be in the same group, the transferee disposing of the relevant asset, or the transferee ceasing to be party to the relevant loan relationship or derivative contract
  • The amount that becomes due on a trigger event is calculated using the formula (A โˆ’ B) ร— O/T, which takes account of any amounts already accelerated by earlier partial trigger events and scales the result by the proportion of total deferred tax still outstanding
  • The instalment period runs from when the CT payment plan is entered into until the date the final instalment of deferred tax is due

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