Commentary

C3.1716 Interaction of holdover relief and PPR relief

Capital gains tax
Capital gains tax | Commentary

C3.1716 Interaction of holdover relief and PPR relief

Capital gains tax | Commentary

C3.1716 Interaction of holdover relief and PPR relief

Anti-avoidance measures exist which are designed to prevent an individual or trustees from claiming principal private residence (PPR) relief on the disposal of a property in respect of which a claim has been made for holdover relief on a gift of the property on which inheritance tax is chargeable (see C3.1601)1. This restriction applies to disposals after 9 December 20032.

The legislation makes some reference to terminology which is defined below3:

TerminologyDefinition
The later disposalA gain on a disposal which attracts PPR relief
The transferorThe individual or trustees making the disposal

The anti-avoidance rules apply if the following

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial