A potential chargeable event (see ¶199-905) involves the disposal of the qualifying investment, either as the event itself or as a mitigation step required to avoid a deemed remittance. The normal rule is that the whole of the proceeds of the disposal must be re-invested or repatriated within the grace period (see ¶199-910).

However, this rule is relaxed to allow funds to be retained to meet any capital gains tax liability arising on that disposal, where the actual (as opposed to deemed) disposal proceeds fall short of the sum of:

the amount which would normally be required to be re-invested/repatriated; and

tax at 28 per cent on the gain arising on that disposal.

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