CTA09/S860

Circumstances where provision applies

This section applies where:

a company holding goodwill or an intangible asset ceases to be resident in the UK,

the asset is deemed to be realised and reacquired at market value under the rule described in CIRD47030,

the asset is held for the purposes of a trade carried on through a foreign permanent establishment,

the market value exceeds the original tax cost of the asset; and

the company and another company, which remains resident in the UK and of which the first company is a 75% subsidiary (see CIRD40030), jointly elect within two years of the change of residence for the provision to apply.

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