Section 109C: Penalty for company's failure to comply with section 109B

If a company ceases to be resident in the United Kingdom at a time before each of conditions A to D in section 109B is met, the company is liable to a penalty not exceeding the amount of tax—

(a) which is or will be payable by it in respect of periods beginning before that time, and

(b) which has not been paid at that time.