Section 859 — Corporation Tax Act 2009: Asset ceasing to be chargeable intangible asset: deemed realisation at market value

Asset ceasing to be chargeable intangible asset: deemed realisation at market value 859 1 If an asset ceases to be a chargeable intangible asset in relation to a company in any of the circumstances specified in subsection (2), this Part applies as if—

a immediately before the asset ceased to be a chargeable intangible asset in relation to the company, the company had realised the asset for its market value at that time, and b the company had immediately reacquired it at that value.

2 The circumstances are—

a that the company ceases to be UK resident, b in the case of a company that is not UK resident, any circumstances not involving the realisation of the asset by the company, and c that the asset begins to be held for the purposes of a mutual trade or business. 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .