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63(1)The general rule is that an appeal under this Part of this Schedule does not postpone any liability to pay multinational top-up tax.
(2)Accordingly, the periods within which tax is payable under paragraph 32 continue to apply notwithstanding an appeal.
(3)But a liability may be postponed if—
(a)a determination is made by HMRC to that effect;
(b)a direction is made by a tribunal to that effect;
(c)HMRC and the appellant agree to a postponement.
(4)The effect of a liability being postponed is that the period within which the tax is payable is extended by the period of the postponement.
(5)The period of the postponement—
(a)may not begin after the date the appeal is determined;
(b)is to end on the date the appeal is determined.
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