TCGA92/S185 imposes a charge to Corporation Tax on the unrealised gains of a company which ceases to be resident in the UK.

In addition roll-over relief is restricted if the new asset is acquired after the company ceases to be UK resident and any gain arising on its immediate deemed disposal would be outside the charge to UK tax.

TCGA92/S185 creates an occasion of charge immediately before the time (the `relevant time') when a company ceases to be resident in the UK. TCGA92/S185 (2) deems the company to have disposed of all its assets at their market value immediately before the relevant time and to have reacquired them at that value at the relevant time.

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