Commentary

C2.1126 Chargeable persons for ATED-related gains

Capital gains tax
Capital gains tax | Commentary

C2.1126 Chargeable persons for ATED-related gains

Capital gains tax | Commentary

C2.1126 Chargeable persons for ATED-related gains

The rules in C2.1125–C2.1129A apply to disposals made prior to 6 April 2019. For disposals made on or after 6 April 2019, see C2.1139–C2.1173. Transitional rules apply to unused losses existing at 6 April 2019 that have accrued on disposals made prior to that date. See C2.1142 for further details.

A person is chargeable to CGT on any ATED-related chargeable gain accruing in a tax year on a relevant high value disposal, unless they are an excluded person1 (see C2.1127). Companies, partnerships with at least one company member and collective investment schemes are all chargeable persons for these purposes. It should be noted that the charge applies to both UK resident and non-resident persons.

Excluded persons for ATED-related gains

The following are excluded persons for these purposes:

  1.  

    •     individuals, trustees of a

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