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UK companies may seek to redomicile their tax residence away from the UK to a country with a more competitive and simpler tax regime. A UK company could redomicile by simply migrating its tax residence (generally speaking, if moving to a jurisdiction with a Double Tax Treaty with the UK, this can be achieved by moving its 'place of effective management' away from the UK). This would give rise to a deemed disposal ('exit' charge) of all its chargeable assets¹.

For companies that leave the UK before 1 January 2020, the charge on such gains (other than those on ATED-related assets; see C2.1125) can be postponed in certain circumstances if an election is made under TCGA 1992, s 187 (see D4.132). This ability to postpone this charge was repealed by Finance Act 2019 as part of a package of measures that were introduced by Finance Act 2019 in order to comply with