Finance Act 2015

21 (1) Section 139 (reconstruction involving transfer of business) is amended as follows. U.K.

(2) In subsection (1A)—

(a) in paragraph (a), after “chargeable assets” insert “ or NRCGT assets ”;

(b) in paragraph (b), after “chargeable assets” insert “ or NRCGT assets ”.

(3) After subsection (1A) insert—

“(1AA) For the purposes of subsection (1A), an asset is an “NRCGT asset” in relation to a company at any time if—

(a) the disposal of the asset by the company at that time would be a non-resident CGT disposal, and

(b) the company would not be, in relation to that disposal, an eligible person (as defined in section 14F).”