The following Tax Q&A provides comprehensive and up to date legal information covering:
For the purposes of this Q&A we have assumed that:
the management company owns the freehold of the block
all residents are shareholders of the management company, and
the granting of the extension is completed via an express surrender and regrant
When the limited company grants the new leases, it will be making part disposals out of its freehold for CGT purposes (strictly, for the purposes of corporation tax on chargeable gains) in consideration of the surrender of the old lease and the lump sum paid by the lessee for the new lease, which would give rise to a chargeable gain. For HMRC's guidance on this, see: HS292 Land and leases, the valuation of land and Capital Gains Tax (2015) and CG70950.
However see HMRC manual CG71240 restates extra statutory concession D39, which explains that:
'In practice, the s
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