Commentary

C2.1127 Relevant high value disposal

Capital gains tax
Capital gains tax | Commentary

C2.1127 Relevant high value disposal

Capital gains tax | Commentary

C2.1127 Relevant high value disposal

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 disposal on which a gain or loss accrues to a person (P) is a relevant high value disposal if conditions A to D are met:

  1.  

    (A)     The disposal is of the whole or part of a chargeable interest1 ('the disposed of interest')

  2.  

    (B)     The disposed of interest has at any time during the relevant ownership period, been or formed part of a single-dwelling interest2

  3.  

    (C)     P, or

    1.  

      •     in the case of a disposal of a partnership asset, the responsible partners3, or

    2.  

      •     in the case of a disposal of an interest in a relevant collective investment scheme, the person with day-to-day control over management of the scheme property,

  4.  

    has been within the charge to ATED4 in respect of that single-dwelling interest on one or more days in the relevant ownership period which are not relievable days (or would have been so within the charge if ATED had commenced on 31 March 1982)5

  5.  

    (D)     The amount or value of the consideration for the disposal exceeds the

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