Migration of companies: postponed charges: example
B Ltd is a 100 per cent subsidiary of A Ltd. It is incorporated outside the UK. Both A Ltd and B Ltd have their central management and control in the UK until 30 April 2004. On that date the central management and control of B Ltd is transferred outside the UK so that the company ceases to be UK resident, see CTM34120. A Ltd and B Ltd make an election under TCGA92/S187 that the exit charge under TCGA92/S185 should be postponed. See CG42370 for guidance on exit charges and CG42390 for guidance on the postponement of exit charges.
The gains and losses on the deemed disposal of B Ltd’s assets on 30 April 2004 are as follows. All the assets are situated outside the UK.
|Asset No 1 gain||10,000|
|Asset No 2 gain||8,000|
|Asset No 3 gain||32,000|
|Asset No 4 loss||(12,000)|
|The postponed gain is thus||38,000|