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Migration gives rise to possible 'exit charges' in relation to a number of tax provisions in the chargeable gains, loan relationships, derivative contracts, corporate intangibles and trading stock fields. These are

• TCGA92/S25, S185 and S187 (4), see and onwards, deemed disposal of assets
  • when a company ceases to be UK resident, or
  • when assets held for the purposes of a trade carried on by a UK permanent establishment cease to be in the UK, or
  • when the trade of a UK permanent establishment ceases;
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• CTA09/S333, S334, S609 and S610, see and , deemed disposal of loan relationships and derivative contracts at fair value by a company,
  • when it ceases to be UK resident, or
  • when it ceases to hold assets or liabilities for the purposes of a trade carried on by a UK permanent establishment;
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• CTA09/S858 and S862,Ìýsee onwards, deemed realisation of intangible fixed assets at market value at the time it
  • ceases to be UK resident, or
  • ceases to hold assets for the purposes of a trade carried on by a UK permanent establishment;
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• CTA09/S162 applied by CTA09/S41 (2)(b), see BIM33470, revaluation of trading stock to open market value when company ceases to be within CT charge (when it migrates, unless the stock remains in a UK permanent establishment).
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Permanent establishment broadly means a branch, agency or other fixed place of business through which the trade is carried on - see .

Tax charges that may be deferred include charges triggered which have already been postponed under the chargeable gains and corporate intangibles regimes, see and .

CTM34131 onwards explains the circumstances in which the exit charges may be deferred.Ìý These rules apply broadly with effect from 11 December 2012.