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A charge to UK tax is levied (an 'exit charge') on a transfer of company residence. The company is deemed to dispose of all capital assets on the date of migration — the net chargeable gain being taxable, except, broadly, to the extent that:

1. Ìý

   •ÌýÌýÌýÌý the assets remain liable to UK taxation of capital gains as UK permanent establishment assets (see D4.116)

2. Ìý

   •ÌýÌýÌýÌý the assets realised an ATED-related gain or loss (C2.1101) chargeable to CGT¹ (see D4.131)²

3. Ìý

   •ÌýÌýÌýÌý the assets would have generated a NRCGT charge (see C2.1101 for disposals made prior to 6 April 2019 and see C2.1139 for disposals made on or after 6 April 2019) if the company were a non-resident company at the time of the deemed disposal (see D4.131)³

The migrating company must make arrangements for securing payment of outstanding tax and must obtain HMRC's approval of those arrangements⁴.

Alternatively it can defer the tax (where certain condition are met) or enter into a CT exit charge payment plan⁵