Migration gives rise to an 'exit charge' on certain unrealised
capital gains and losses under TCGA92/S185 (see CG42430 to
CG42457).
The occasion of migration may well also result in the company
ceasing to be within the charge to corporation tax in respect of
its trade in which case the provisions of ICTA88/S337 (1) apply.
This means the company is treated as if the trade is ceasing so,
balancing charges or allowances arise on plant and machinery unless
they are left in a trading branch in the UK (CA26500), and on
mineral extraction assets (CA50420).
The provisions of ICTA88/S100 apply to the valuation of
trading stock at discontinuance, unless it is left in a branch in
the UK (BIM33470).
