Paragraph 3 F1

a disposal within sub-paragraph (2),

a transaction within sub-paragraph (3),

a transaction within sub-paragraph (4), and

a transfer within sub-paragraph (5).

it is a disposal by the company concerned of an asset,

it is a disposal to a company (“the transferee”) that at the time of the disposal is resident outside the United Kingdom in an EEA state, and

it is a disposal to which section 139 or 171 of TCGA 1992 would apply were the transferee resident at the time of the disposal in the United Kingdom instead.

it is a transaction, or the first in a series of transactions, as a result of which the company concerned is directly or indirectly replaced as a party to a loan relationship by another company (“the transferee”),

at the time of the transaction the transferee is resident outside the United Kingdom in an EEA state, and

it is a transaction to which section 340(3) of CTA 2009 would apply were the transferee resident at the time of the transaction in the United Kingdom instead.

it is a transaction, or the first in a series of transactions, as a result of which the company concerned is directly or indirectly replaced as a party to a derivative contract by another company (“the transferee”),

at the time of the transaction the transferee is resident outside the United Kingdom in an EEA state, and

it is a transaction to which section 625(3) of CTA 2009 would apply were the transferee resident at the time of the transaction in the United Kingdom instead.

it is a transfer from the company concerned of an intangible fixed asset,

it is a transfer to a company (“the transferee”) that immediately after the transfer is resident outside the United Kingdom in an EEA state, and

it is a transfer to which section 775(1) of CTA 2009 would apply were the transferee resident immediately after the transfer in the United Kingdom instead.