The general principle behind TCGA 1992 section 140 is that where

a UK company within the charge to corporation tax on capital gains

transfers assets that it used in a trade through a permanent establishment (a PE) outside the UK in exchange for securities issued by the transferee

to a company that is not resident in the UK.

Then provided all of the other relevant conditions are met any charge to tax on the disposal by the transferor company is deferred until there is a disposal of the securities that the transferor company received in the transferee. See CG45733 and CG45660+ for a fuller explanation.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.