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HMRC internal manual

Oil Taxation Manual

HM Revenue & Customs
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Capital gains: non residents: exit charges for branches


TCGA92\S25 applies to events on or after 14 March 1989 and deems a disposal by a non-resident to occur when assets cease to be chargeable assets by virtue of the cessation of the company’s trade carried on in the UK through a branch or agency.

TCGA92\S25(2)(b) excludes exploration or exploitation assets from the general charge on the occasion of assets being situated outside the UK. This provides consistency with the treatment in TCGA92\S276(4) and is achieved by special rules for the oil industry introduced in TCGA92\S199.

It should be noted that exploration or exploitation assets are those used in connection with exploration or exploitation activities carried on in the UK or UK Continental Shelf, as defined for TCGA92\S276. Therefore the restricted application to offshore areas discussed at OT30820 applies.