Commentary

C3.509 Holdover relief for gifts of business assets—gifts of direct or indirect interests in UK land to non-residents

Capital gains tax
Capital gains tax | Commentary

C3.509 Holdover relief for gifts of business assets—gifts of direct or indirect interests in UK land to non-residents

Capital gains tax | Commentary

C3.509 Holdover relief for gifts of business assets—gifts of direct or indirect interests in UK land to non-residents

A disposal of direct or indirect interests in UK land (before 6 April 2019 and after 6 April 2015, a UK residential property interest) to a transferee who is not resident in the UK qualifies for relief1. This is because the disposal of such an interest by a non-resident is chargeable to capital gains tax (see C2.1131, C2.1136) so the held-over gain will not be taken outside the UK tax net (see C3.510).

The legislation indicates that the full amount of the

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