Taxable credits arising on the deemed realisation of an asset
(for example on the emigration of a company - see
CIRD47030) are outside the scope of
reinvestment relief. This exclusion is subject to exceptions where
the deemed realisation arises in connection with
‘degrouping’ (see
CIRD20460 onwards).
CG on existing assets (
CIRD20050) arising on a deemed disposal
are similarly outside the scope of reinvestment relief. But again
there are exceptions where the deemed disposal arises in connection
with degrouping (see
CIRD20480).
Occasions where there is a deemed realisation or disposal of an
asset need to be distinguished from those where there is an actual
realisation or disposal but the amount receivable for CT purposes
is some figure, normally market value, which is different from the
actual amounts.
The only restriction on reinvestment relief in these
circumstances is that described in
CIRD20080, on the part realisation of a
chargeable intangible asset to a related party.
