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Budget 2013: Deloitte comments on the deferral of the corporation exit tax

21 March 2013

Alison Lobb, Director in Deloitte’s tax policy group, said:  

“It is disappointing that the new options on the deferral of corporation exit tax do not seem to bring the UK law fully in line with European Court of Justice’s decision, in particular because tax is not deferred in all cases until the ultimate disposal of the assets. Instead, the UK is offering payment by instalments.

“The question for businesses going forward will be whether the sums involved are sufficiently large to warrant expensive further European litigation. There is also the possibility that the European Commission may want to take the UK to the European Court, if the new legislation is enacted in its current form.

“The Government has made limited amendments to the UK law on exit tax for companies following the decision of the European Court of Justice in National Grid Indus. The European Court ruled that a company transferring its tax residence within the European Economic Area (EEA) should be allowed to defer tax due on the deemed sale of its assets until the assets are sold.   

“There are two new proposals (both optional) for instalment payments of exit charges over periods up to ten years where companies move tax residence within the EEA. Both options carry interest charges on the postponed tax.”


Notes to editors
Follow us online

Deloitte’s Budget coverage will be on our dedicated website You can also follow us on Twitter: @ukbudget where Bill Dodwell, head of tax policy at Deloitte, gives regular views.  

Deloitte spokespeople
The following experts from Deloitte are available now and on the day of the Budget for comment. Please call the Deloitte Budget Press Hotline on 020 7007 3333, where you will be directly connected to one of our spokespeople:

Bill Dodwell - Business taxation and general topics
Daniel Lyons - Indirect and green taxes
Patricia Mock - Personal taxes
John Cullinane - Banking
Anne Hamilton - Insurance
Debbie Griffiths - Entrepreneurial businesses and SMEs
Mark Groom - Employer taxes
Phil Nicklin - Property taxation and REITs
Roman Webber - Oil and Gas
Nick Prior - Infrastructure
Ian Stewart - Economics

About Deloitte
In this press release references to Deloitte are references to Deloitte LLP, which is among the country's leading professional services firms.

Deloitte LLP is the United Kingdom member firm of Deloitte Touche Tohmatsu Limited (“DTTL”), a UK private company limited by guarantee, whose member firms are legally separate and independent entities.

Please see for a detailed description of the legal structure of DTTL and its member firms.

The information contained in this press release is correct at the time of going to press.

Member of Deloitte Touche Tohmatsu Limited

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