The relief generally applies to gifts by an individual (referred to here as 'the transferor')1 to a person ('the transferee') who is resident in the UK, though gifts of UK land to non-residents also qualify (see C3.509)2. There is no requirement that the transferor is UK resident so the following disposals can qualify for the relief:
• a non-resident CGT disposal (ie one relating to UK land)3 (see C2.1131, C2.1139)
• a disposal of assets situated in the UK for use in a trade, profession or vocation carried on through a UK branch or agency (see C1.602)
In addition, relief is also available for following:
• disposals by a partnership, because the disposal is deemed to be made by the individual partners4
• certain disposals by trustees (see C3.506)
The assets in respect of which holdover relief under TCGA 1992, s 165 may
Web page updated on 17 Mar 2025 15:57
