Paragraph 21

(1)

Section 139 (reconstruction involving transfer of business) is amended as follows.

(2)

In subsection (1A)—

(a)

in paragraph (a), after “chargeable assets” insert “ or NRCGT assets ”;

(b)

in paragraph (b), after “chargeable assets” insert “ or NRCGT assets ”.

(3)

After subsection (1A) insert—

“(1AA)
For the purposes of subsection (1A), an asset is an “NRCGT asset” in relation to a company at any time if—
(a)
the disposal of the asset by the company at that time would be a non-resident CGT disposal, and
(b)
the company would not be, in relation to that disposal, an eligible person (as defined in section 14F).”