Holdover relief is not always available, or not available in full, even where the initial conditions are met.
Restrictions on relief—qualifying corporate bonds
Holdover relief is not available in relation to a disposal of assets within TCGA 1992, s 115(1) (qualifying corporate bonds) on which a gain is deemed to accrue by virtue of TCGA 1992, s 116(10)(b)1.
Restrictions on relief—consideration given
If actual consideration is provided for a disposal (for example a gift at undervalue) and this exceeds the allowable expenditure2 then the 'cash gain' is immediately taxed to CGT and the held-over gain will be restricted by that amount3. For further details and an example see C3.1602.
Restrictions on relief—residence
As the held-over gain is effectively transferred to the transferee, it is provided that the transferee must be within the
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 17:41