TCGA92/S140 (4), (4A) and (5)

CG45660 explains how chargeable gains may be deferred on an outward domestication. Chargeable gains and allowable losses are aggregated to produce a net chargeable gain, which is then deferred.

The deferred gain is released for assessment when

there is a disposal of shares or loan stock by the transferor company, or

if the non-UK resident transferee company disposes of the underlying permanent establishment assets within six years of the transfer.

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