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HMRC internal manual

Capital Gains Manual

Migration of companies: restriction of roll-over relief on ceasing UK residence

TCGA92/S185 (3)

If a company which ceases to be resident

  • disposes of `old assets’ before it migrates,
  • acquires `new assets’ after it migrates

TCGA92/S185 (3) prevents it from rolling over the gains under the provisions of TCGA92/S152, see CG60250+. The restriction does not apply if the new assets are assets of a permanent establishment which are exempted from the exit charge by TCGA92/S185 (4), see CG61350.