CG13400 - Migration and exit charges: no general exit charge

Capital Gains Tax is charged

• on the disposal of assets
• on certain events giving rise to deemed disposals
• on certain events causing held over gains to be brought into charge.

A person moving abroad and ceasing to be resident and ordinarily resident* ceases, in general, to be within the charge to Capital Gains Tax. But if that person retains the ownership of their assets they do not make a disposal on leaving the UK. Therefore there can be no CGT charge unless legislation deems the departure to be an event giving rise to a deemed disposal or causing held over gains to be brought into charge.

There is no legislation applying to all categories of person which deems the cessation of residence and ordinary residence in the UK to be an event giving rise to a deemed disposal. It is therefore necessary to consider separately the legislation applying to:

individuals, see CG13420,

companies, see CG13430+,

trustees, see CG13440+.

As far as held over gains are concerned, see CG13410.

Certain assets remain within the scope of charge when a person leaves the UK e.g. an interest in UK resdential property. Guidance on the interactions with any exit charge that would arise is at CG73834 and CG73769 where the exit was before 6 April 2019 and at CG73988 where the exit was on 6 April 2019 or later.

* For 2013/14 and subsequent years ordinary residence does not need to be considered.