Arrangements should have been made before migration for payment of an agreed amount of tax payable by the company up to migration (¶194-600). Failure to make such arrangements would result in penalties being levied (¶194-625) but this would not recover the tax itself.

A liability for tax may therefore arise:

in the event that HMRC could not recover the agreed amount under the approved arrangements;

if no such arrangements were made; or

to the extent that the actual liability exceeds the amount agreed for the purposes of approval of arrangements.

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