Taxes Management Act 1970 section 59FA

CT exit charge payment plans

Section 59FA introduces the framework that allows companies to defer payment of certain corporation tax liabilities when they move their tax residence out of the United Kingdom or cease trading through a UK permanent establishment.

• Companies may enter into a CT exit charge payment plan to defer payment of corporation tax that arises on leaving the UK or ceasing UK operations through a permanent establishment.
• Part 1 of Schedule 3ZB sets out when a company that ceases to be UK resident may use a plan, and how the deferrable tax is calculated.
• Part 2 of Schedule 3ZB makes equivalent provision for non-UK-resident companies that carry on, or have carried on, a trade in the UK through a permanent establishment.
• Part 3 of Schedule 3ZB covers the mechanics of the plan, including how to enter into one, its legal effect, its required content, and the permitted methods for paying the deferred tax.