Commentary

C3.1605 Holdover relief for gifts of non-business assets—transferee with dual resident status

Capital gains tax
Capital gains tax | Commentary

C3.1605 Holdover relief for gifts of non-business assets—transferee with dual resident status

Capital gains tax | Commentary

C3.1605 Holdover relief for gifts of non-business assets—transferee with dual resident status

For holdover relief to apply, the transferee must generally be resident in the UK1, although relief is also available for gifts of direct or indirect interests in UK land (before 6 April 2019 and after 5 April 2015, UK residential property interests) to non-residents2, see C3.1603. There is a further restriction where the transferee is also resident in another territory with which the UK has entered into a double taxation agreement. If the effect of the double taxation agreement is to treat the transferee as resident in the

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