Part 8U.K.Intangible fixed assets

Modifications etc. (not altering text)

Chapter 11U.K.Transfer of business or trade

Transfer of assets to non-UK resident companyU.K.

829Charge on subsequent realisationsU.K.

(1)If at any time after the transfer the transferor realises the whole or part of the securities held by it immediately before that time, the transferor must bring into account for tax purposes a credit equal to the whole or the appropriate proportion of the total deferred gain.

(2)In subsection (1)—

(3)If at any time within 6 years after the transfer the transferee realises all or some of the relevant assets held by it immediately before that time, the transferor must bring into account for tax purposes a credit equal to the whole or the appropriate proportion of the total deferred gain.

(4)In subsection (3)—

(5)For the purposes of subsection (4) the deferred gain attributable to relevant assets means the sum of the amounts by which the proceeds of realisation of those assets were reduced under section 828(2) or (3).

(6)For cases where transfers are ignored for the purposes of subsection (1) or (3), see section 830.