If, following relief on the transfer of assets to a non-resident (see ¶35300), the transferee disposes of the whole or part of the assets received within six years of the transfer, the transferor is assumed to make a chargeable gain. The fraction of the deferred gain brought into account on a part disposal is the proportion of the capital gain deferred on the part disposed of to the total chargeable gain on the whole of the assets held immediately before the disposal (but see also ¶35330).


Assume the same facts as contained in the example in ¶35300.

In 2012, S Inc disposes of the buildings, which it received on the merger, for £60,000.

Market value


Want to read more?

This content requires a Croner-i Tax and Accounting subscription.

Existing subscriber? Log in

No subscription?

Contact us to discuss your requirements.