Section 184J — Taxation of Chargeable Gains Act 1992: Asset subject to EU exit charge on becoming chargeable asset

Asset subject to EU exit charge on becoming chargeable asset 184J 1 This section applies if—

a an asset becomes a chargeable asset in relation to a company by reason of an event specified in subsection (2),

and b on the occurrence of that event the company becomes subject to an EU exit charge in relation to the asset.

2 The events are—

a the company becoming resident in the United Kingdom, and b 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.

3 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.

4 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. 5 “ 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.