D2.345 Group capital gains—recovery of tax from other group members
HMRC can recover unpaid corporation tax on chargeable gains from other group members or, in certain cases, a controlling director, where1:
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•ÌýÌýÌýÌý the gain accrues either to a company that is UK resident or (to a non-UK resident company) on an asset that is within the charge to UK corporation tax at the time of accrual2, and
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•ÌýÌýÌýÌý all or part of the corporation tax assessed on the taxpayer company for the accounting period in which the gain accrues remains unpaid six months after it became payable
HMRC may serve on any of the following persons a notice requiring that person to pay, within 30 days of service of the notice, the unpaid tax or, if less, an amount equal to corporation tax on the chargeable gain
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