Commentary

C2.1153 Indirect disposals—substantial indirect interest

Capital gains tax
Capital gains tax | Commentary

C2.1153 Indirect disposals—substantial indirect interest

Capital gains tax | Commentary

C2.1153 Indirect disposals—substantial indirect interest

A non-resident person has a substantial indirect interest if they (together with persons connected to them) have held an investment of 25% or more in the company at any point in the two years prior to the disposal unless this was for an insignificant period1.

As a general rule, HMRC consider 'insignificant' to be 10% or less of the time (so 75 days or less for a full two year period). Where the total ownership period is very brief and the facts and circumstances indicate that the person was never intended to hold a 25% or

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