Commentary

D1.895 Cessation of UK residence

Corporate tax
Corporate tax | Commentary

D1.895 Cessation of UK residence

Corporate tax | Commentary

D1.895 Cessation of UK residence

Where a company ceases to be resident in the UK after 16 March 2004, it is deemed to have disposed of and reacquired at a fair value the rights and liabilities under its derivative contracts1. This rule does not apply if the rights and liabilities continue to be held by the company for the purposes of a UK permanent establishment and for times on or after 1 January 2020 where the company remains a party to the derivative contract for the purposes of (i) its trade of dealing in or developing UK land; (ii) for

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