Commentary

D2.245 Recovery of tax payable by a non-resident company

Corporate tax
Corporate tax | Commentary

D2.245 Recovery of tax payable by a non-resident company

Corporate tax | Commentary

D2.245 Recovery of tax payable by a non-resident company

There are provisions that allow HMRC to recover an unpaid tax liability of a non-resident company from another group company. The rules are adapted where a member of a consortium (or a member of the same group as a consortium member) which owns the non-resident company. In such cases, the amount that can be recovered is calculated by reference to the member's share in the consortium.

The specific measures1 provide for tax payable by a non-resident company to be recovered from another company within the same group when:

  1.  

    •     any corporation tax that has been assessed on a non-resident company remains unpaid six months after it became payable2,

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