Taxes Management Act 1970 Schedule 3ZB paragraph 13

All of outstanding balance attributable to particular exit charge asset or liability due

Paragraph 13 of Schedule 3ZB sets out what happens when an entire exit charge asset or liability is disposed of or ceases to be used in an EEA business during the instalment period, triggering an accelerated payment of the outstanding ECPP tax attributable to that asset or liability.

• A trigger event occurs when a company disposes of an exit charge asset, ceases to be party to a relevant loan relationship or derivative contract, or stops holding the asset for a business in a relevant EEA state without transferring it to another such business
• If a trigger event occurs and no previous trigger event has happened for that asset or liability during the instalment period, an accelerated amount of ECPP tax becomes due immediately
• The amount due is calculated using the formula (A − B) × O/T, where A is the ECPP tax attributable to the asset or liability, B is any amount previously accelerated due to partial trigger events, O is the ECPP tax still outstanding, and T is the total ECPP tax
• The instalment period runs from immediately after the company ceases UK residence (Part 1 companies) or the PE qualifying event (Part 2 companies) until the date the final instalment is due under the payment plan