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HMRC internal manual

Capital Gains Manual

Disposal of assets: deemed disposals

There are times when although no disposal has actually taken place a person is deemed to have disposed of an asset. This creates occasions of charge which would not otherwise have existed. For example, in connection with

  • value shifting, see CG58850+, CG13260+, CG46820+ and CG46880+
  • company migration, see CG42300+
  • trustees ceasing to be resident in the UK or ceasing to be liable to UK tax by becoming dual resident, see CG38215
  • a non-resident person (other than a company) carrying on business through a UK branch or agency, see CG25500+
  • a non-resident company carrying on a trade through a UK permanent establishment, see CG42100+
  • a company leaving a group and taking with it assets transferred to it by other group members in the previous 6 years, see CG45400+
  • appropriations to and from trading stock, see CG69200+
  • a person becoming absolutely entitled to any settled property as against trustees, see CG37000+
  • the death of a person entitled to a life interest in possession in all or any part of settled property (if the property remains settled property), see CG36450+
  • a claim by the owner of an asset that it is of negligible value, see CG13120+.