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Official guidance
Capital Gains Manual

CG42300P · Capital Gains Manual: Companies and Groups of Companies: Effects of residence and migration on companies: Migration of companies

  • CG42300 · Migration of companies: company residence
  • CG42301 · Migration of companies: company residence: pre- 15/3/88
  • CG42302 · Migration of companies: company residence: 15/3/88-29/11/93
  • CG42303 · Migration of companies: company residence: from 30/11/93
  • CG42310 · Migration of companies: changing a company's residence: pre-15/3/88
  • CG42311 · Migration of companies: changing a company's residence: 15/3/88-29/11/93
  • CG42313 · Migration of companies: changing a company's residence: from 30/11/93
  • CG42315 · Migration of companies: residence: settlement of liabilities
  • CG42320 · Migration of companies: residence: company becoming dual resident
  • CG42321 · Migration of companies: residence: company becoming treaty non-resident
  • CG42350 · Migration of companies: arrivals in UK: becoming resident in UK
  • CG42360 · Migration of companies: departures from UK: ceasing to be resident in UK
  • CG42370 · Migration of companies: exit charges
  • CG42380 · Migration of companies: restriction of roll-over relief on ceasing UK residence
  • CG42390 · Migration of companies before January 2020: postponement of exit charges
  • CG42400 · Migration of companies before January 2020: recovery of charges postponed under TCGA92/S187
  • CG42410 · Migration of companies before 1 January 2020: postponed charges: example
  • CG42420 · Migration of companies before 1 January 2020: recovery of postponed charges: example
  • CG42430 · Migration of companies before January 2020: reduction of recovery charge for unused losses
  • CG42312 · Migration of companies: changing a company's residence: 15/3/88-29/11/93
  • CG42314 · Migration of companies: changing a company's residence: from 30/11/93
  1. Capital Gains Manual: Companies and Groups of Companies: Effects of residence and migration on companies: Migration of companies: Contents
  2. Migration of companies before 1 January 2020: recovery of postponed charges: example

CG42420 | Migration of companies before 1 January 2020: recovery of postponed charges: example

From HM Revenue & Customs · Capital Gains Manual

The example at CG42410 shows how to calculate a postponed gain. This example follows on from that one to illustrate how a postponed gain may be brought back into charge in whole or in part. See CG42400 for guidance on the recovery of postponed gains.

In May 2006 B Ltd sells asset No 2. A gain is deemed to accrue to A Ltd at that time in the following amount

  • Postponed gain (£38,000) multiplied by postponed gain on asset No 2 (£8,000) divided by aggregate of all gains on all relevant assets (£50,000) = £6,080

Postponed gains so far unreleased = £38,000 - £6,080 = £31,920

In June 2008 B Ltd sells asset No 3. A gain is deemed to accrue to A Ltd at that time in the following amount

  • Postponed gain so far unrealised (£31,920) multiplied by postponed gain on asset No 3 (£32,000) divided by aggregate of all postponed gains on all unrealised assets (Nos 1 and 3) (£42,000) = £24,320

Postponed gains so far unreleased = £31,920 - £24,320 + £7,600.

Note that if there is no disposal of asset No 1, or any disposal of shares in B Ltd by A Ltd, within 6 years of the relevant time the remaining part of the postponed gain is not recovered.

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