Taxes Management Act 1970 section Sch 3ZB para 14

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

Section Sch 3ZB paragraph 14 deals with what happens when a partial trigger event occurs during the instalment period in relation to an exit charge asset or liability, requiring a proportionate amount of outstanding exit charge payment plan tax to become due.

  • A partial trigger event accelerates part of the outstanding ECPP tax where a company partially disposes of, or reduces the value of, an exit charge asset or liability during the instalment period
  • For capital gains and trading stock exit charge assets, a partial trigger event occurs when the company disposes of part, but not all, of the asset
  • For financial exit charge assets or liabilities, a partial trigger event occurs on a related transaction involving a disposal of a right or liability under a loan relationship or derivative contract; for intangible exit charge assets, it occurs when a transaction reduces the accounting value without the asset ceasing to be recognised on the balance sheet
  • The amount of ECPP tax that becomes due on a partial trigger event is whatever is just and reasonable, having regard to the amount that would have been due had a full trigger event occurred instead

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