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:
- Ìý
•ÌýÌýÌýÌý any corporation tax that has been assessed on a non-resident company remains unpaid six months after it became payable2, and
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•ÌýÌýÌýÌý HMRC have issued a notice to recover the unpaid tax
HMRC have three years from the date on which the liability of the non-resident company is finally determined
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Web page updated on 17 Mar 2025 15:42