CG12703 | Disposal of assets: deemed disposals

There are times when although no disposal has actually taken place a person is treated as having disposed of an asset. This is known as a deemed disposal and creates an occasion of charge which would not otherwise have existed. The following (non-exhaustive) list contains some examples of deemed disposals:

• a capital sum derived from an asset, see CG12960

• the entire loss, destruction dissipation or extinction of an asset, see CG13120P

• a claim by the owner of an asset that it is of negligible value, see CG13120P

• the satisfaction of a debt, see CG53405

• appropriations to and from trading stock, see CG47970

• value shifting, see CG58850P, CG13260+

• a person becoming absolutely entitled to any settled property as against trustees, see CG37000C

• the death of a person entitled to a life interest in possession in all or any part of settled property (if the property remains settled property), see CG36450P

• trustees ceasing to be resident in the UK or ceasing to be liable to UK tax by becoming dual resident, see CG38200SUBC

• company migration, see CG42300P

• a non-resident person (other than a company) carrying on business through a UK branch or agency, see CG25500P

• a non-resident company carrying on a trade through a UK permanent establishment, see CG42100P

• a company leaving a group and taking with it assets transferred to it by other group members in the previous 6 years, see CG45400P

This list may not be exhaustive. If you encounter a scenario not covered in this list, it is important to consider whether the statute and guidance in this manual provides an answer.