186Deemed disposal of assets on company ceasing to be liable to U.K. taxation
(1)This section and section 187 apply to a company if, at any time (“the relevant time”), the company, while continuing to be resident in the United Kingdom, becomes a company which falls to be regarded for the purposes of any double taxation relief arrangements—
(a)as resident in a territory outside the United Kingdom; and
(b)as not liable in the United Kingdom to tax on gains arising on disposals of assets of descriptions specified in the arrangements (“prescribed assets”).
(2)The company shall be deemed for all purposes of this Act—
(a)to have disposed of all its prescribed assets immediately before the relevant time; and
(b)immediately to have reacquired them,
at their market value at that time.
(3)Section 152 shall not apply where the new assets are prescribed assets and the company—
(a)has disposed of the old assets, or of its interest in those assets, before the relevant time; and
(b)acquires the new assets, or its interest in those assets, after that time,
and in this section “the old assets” and “the new assets” have the same meanings as in section 152.