Taxes Management Act 1970 Schedule 3ZB paragraph 4

Circumstances in which CT exit charge payment plan may be entered into

Paragraph 4 of Schedule 3ZB sets out the conditions under which a non-UK resident company trading in the UK through a permanent establishment may enter into a CT exit charge payment plan to defer corporation tax arising from certain qualifying events affecting its assets or liabilities.

• A non-UK resident company trading through a UK permanent establishment may defer qualifying corporation tax by entering into a CT exit charge payment plan when a PE qualifying event occurs during the relevant accounting period
• The company must apply to HMRC within 9 months of the end of the migration accounting period, providing all details required under Part 3 of the Schedule
• A PE qualifying event is an event triggering a deemed disposal and reacquisition, or a revaluation, of an asset or liability, provided the company is not treated as resident outside the EEA under double taxation arrangements at the time of the event
• Immediately after the event, the asset or liability must be held for the purposes of a permanent establishment in a relevant EEA state, or held by a company that is itself resident in a relevant EEA state