Holdover relief is not always available, or not available in full, even where the initial conditions are met.
Firstly, If holdover relief is available under TCGA 1992, s 260 (see I3.613) then that section will apply in preference and relief under TCGA 1992, s 165 will not be available1.
Restrictions on relief—qualifying corporate bonds
Holdover relief is not available in relation to a disposal of qualifying corporate bonds on which a gain is deemed to accrue by virtue of TCGA 1992, s 116(10)(b)2 .
Restrictions on relief—transferee is a company
Where the disposal is of shares or securities, relief is not available where the transferee is a company3 (for disposals after 20 October 2003).
Restrictions on relief—consideration given
If actual consideration is provided for a disposal (for example a gift at undervalue) and this exceeds the allowable expenditure4 then the 'cash gain' is immediately taxed to CGT and the held-over gain will be restricted by that
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