Commentary

C3.510 Holdover relief for gifts of business assets—residence status of transferee

Capital gains tax
Capital gains tax | Commentary

C3.510 Holdover relief for gifts of business assets—residence status of transferee

Capital gains tax | Commentary

Holdover relief for gifts of business assets—anti-avoidance provisions

C3.510 Holdover relief for gifts of business assets—residence status of transferee

A number of provisions limit the scope for making holdover claims where the effect would be to take gains outside the UK tax net. Relief is not generally available where the transferee, including a company, is not resident in the UK1, although gifts of UK land to non-residents may qualify for relief (see C3.509). Relief given on a disposal to a transferee who ceases to be UK resident after the date of the disposal may be clawed back under the

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