Commentary

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

Capital gains tax
Capital gains tax | Commentary

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

Capital gains tax | Commentary

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

It is possible for a gain or loss on a disposal to be exempted under both the exemption election and under other capital gains exemptions including the substantial shareholding exemption and the exemption for capital disposals by UK real estate investment trusts (REITs).

Where the rules both apply, there are provisions that provide which exemption has priority and also how the different exemptions are to be calculated generally.

Interaction with the substantial shareholding exemption

The exemption election and substantial shareholding exemptions can interact in the case of a company making an indirect disposal of UK land where1:

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