Section 184J: Asset subject to EU exit charge on becoming chargeable asset

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part VI: Companies, oil, insurance etc. — Chapter I: Companies

This section applies if—

an asset becomes a chargeable asset in relation to a company by reason of an event specified in subsection (2), and
on the occurrence of that event the company becomes subject to an EU exit charge in relation to the asset.

The events are—

the company becoming resident in the United Kingdom, and
in the case of a company that is not resident in the United Kingdom, the asset beginning to be held for the purposes of a trade carried on by the company in the United Kingdom through a permanent establishment.

The company is to be treated for the purposes of this Act as if it had acquired the asset for its market value at the time it became a chargeable asset in relation to the company.

For the purposes of this section an asset is a "chargeable asset" in relation to a company at any time if any gain on its disposal by the company at that time would be chargeable to corporation tax.

"EU exit charge" means a charge to tax under the law of a member State in accordance with Article 5(1) of Directive (EU) 2016/1164 of the European Parliament and of the Council of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market.

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Reuse reviewed 21 August 2026 under Open Government Licence v3.0.