656. Penalties in connection with companies ceasing to be UK resident.

If a company ceases to be resident in the United Kingdom at a time before each of the statutory conditions1 is met, the company is liable to a penalty not exceeding the amount of tax which is or will be payable by it in respect of periods beginning before that time and which has not been paid at that time2.

Where, in relation to a company ('the migrating company') any person ('P') does or is party to the doing of any act which to P's knowledge amounts to or results in, or forms part of a series of acts which