Specific provisions apply for the recovery of unpaid corporation tax due by a non-resident company (which could include amounts in respect of chargeable gains arising in respect of disposals of assets held by a UK trading branch or agency operated by the non-resident group company) (CTA 2010, s. 973).

‘Unpaid corporation tax’ for this purpose is defined as any amount not settled six months after the due date for payment (CTA 2010, s. 974(1)). There are three types of related company which can be liable for the unpaid tax:

any company in the same group as the non-resident;

any member of a consortium which owns the non-resident; and

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