Commentary

C2.1152 Indirect disposals—trading exemption

Capital gains tax
Capital gains tax | Commentary

C2.1152 Indirect disposals—trading exemption

Capital gains tax | Commentary

C2.1152 Indirect disposals—trading exemption

An exemption is available in respect of indirect disposals of property rich companies where, at the time of the disposal, at least 90% of the market value of the UK land being disposed of is1:

  1.  

    •     being used in the course of a 'qualifying trade', or

  2.  

    •     if not currently being used, was acquired for the future use in the trade

HMRC suggest that the threshold is to allow for cases where, for example, a small amount of the value of UK land represents a dwelling for occupation by a member of staff, or where there are

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