Taxes Management Act 1970 section Sch 3ZC para 12

Part of outstanding balance attributable to particular qualifying transaction due

Section Sch 3ZC paragraph 12 deals with what happens when a partial trigger event occurs during the instalments period in relation to a qualifying transaction listed in a CT payment plan, and sets out how much deferred tax becomes due as a result.

  • A partial trigger event arises where only part of an asset, loan relationship, derivative contract or intangible fixed asset that is the subject of a qualifying transaction is disposed of or reduced in value, rather than being fully disposed of or derecognised.
  • This paragraph only applies if no full trigger event has already occurred for that qualifying transaction during the instalments period.
  • When a partial trigger event occurs, a proportion of the deferred tax becomes payable โ€” the amount must be just and reasonable, calculated by reference to what would have been due had a full trigger event occurred instead.
  • For intangible fixed assets that have no balance sheet value (or no longer have one), the rules apply as though the asset did have a balance sheet value immediately before the subsequent transaction took place.

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