[2024] UKUT 00319 (TCC)

Finance Act 2013 (“FA 13”) provided that TMA be amended by the inclusion of a new Schedule 3ZB (“Sch 3ZB”). Sch 3ZB provides that where a company ceased to be UK tax resident, it could enter into an agreement with HMRC for the payment of any exit taxes (including the liability under s185 TCGA) in six equal instalments over five years: the first instalment payable nine months after the company ceased to be resident, and the subsequent instalments paid at 12-monthly intervals thereafter. FA 13 provided that that Sch 3ZB was treated as having come into force on 11 December 2012 in relation to an accounting period if the relevant day, in relation to that period, fell on or after 11 December 2012 (Footnote: ⁴).