This rule does not apply where a company migrates on or after 1 January 2020.

Where a company migrates before 1 January 2020, the charge on deemed disposals under TCGA92/S185 (CG42370) may be partly or wholly postponed if the following conditions apply immediately after the relevant time

assets are situated outside the UK and are used in or for the purposes of a trade carried on outside the UK (`foreign assets'),

the chargeable company is a 75 per cent subsidiary of a company which is resident in the UK, the `principal company',

the chargeable company and the principal company elect for postponement within two years of the relevant time.

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