Jurisdiction(s):
United Kingdom

Key definition

Authority definition

What does Authority mean? In practice, Authority refers to the public sector client that procures and manages a project or service and is the named counterparty in the contract. In public procurement, PFI/PPP, DBFM/DBFOM and outsourcing documents, it is a contractual shorthand for the “contracting authority” defined in legislation (England & Wales and Northern Ireland: Public Contracts Regulations 2015; Scotland: Public Contracts (Scotland) Regulations 2015; Ireland: European Union (Award of Public Authority Contracts) Regulations 2016). Typical Authorities include a local authority, an NHS trust or health board, a central government department or minister, a non‑departmental public body or agency, or another body...

HMRC notice under TMA 1970 s 109B: company ceasing UK residence; template letter seeking approval of arrangements to pay UK tax liabilities, with guarantee and attorney

Published by a LexisNexis Tax expert

Precedents

[send by email to the address shown in HMRC manual CTM34195]

[ Date ]

Dear [ insert organisation name ]

Notification of intention to migrate — [ Company name, address, place of incorporation, tax district and unique taxpayer reference ]

1 Background to notification and our Authority to act as agent

1.1 Acting for our client, [ company name ] (the Company), and pursuant to section 109B of the Taxes Management Act (TMA) 1970, we notify HMRC that the Company proposes to become non‑UK resident and request approval for arrangements to settle the Company’s tax Liabilities.

1.2 The Company plans to migrate from the UK with effect from [ insert date of migration ] (the ‘Migration Date’).

1.3 The Company has authorised us to act on its behalf in respect of this notification and associated approval request. Enclosed at Appendix 1 is the Company’s [ signed authority OR Form 64–8 ], permitting HMRC to deal directly with us. Our telephone and email contact details are provided at the foot of this letter...

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Joshua Critchlow

Freshfields

Josh Critchlow is an International Law Clerk at Freshfields based in New York, qualified as a solicitor in England & Wales. Josh is experienced in advising on UK and international tax aspects of a range of cross-border transactions. ...

Web page updated on 22/05/2026

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