CG73816 - Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Companies: Special rules: Reconstruction involving transfer of business

TCGA92/S139 is concerned with company reconstructions involving the transfer of a business. It allows companies to dispose of assets for no gain and no loss on a scheme of reconstruction (see CG52800+). This is extended under the 2015 changes, so that assets which would be chargeable to non-resident CGT on a subsequent disposal are included among the assets to which this provision applies.