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HMRC internal manual

Company Taxation Manual

CTM34080 - Residence: inward company migration: capital gains

A UK resident company is liable to Corporation Tax in respect of gains arising on chargeable assets wherever they are situated.  In calculating the gain, the base cost is usually the historical cost as adjusted for enhancement expenditure  allowance and so forth.  The market value of the asset at the date the company became resident may apply in certain circumstances, see .