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Exits within 3 months

If the occasion of charge is within one quarter (three months) of the commencement of the settlement, the 'appropriate fraction' would be zero¹. However, there is a total exception from charge in these circumstances (I5.331).

The fact that there is a total exception from charge, rather than a charge at 0%, can be of critical importance where a particular relief depends upon an event being a chargeable one (for example holdover relief under TCGA 1992, s 260).

Identifying mixed relevant property

Where different parts of the settled property become relevant property comprised in the settlement at different times, there are no rules for identifying the property which acquired that character at any particular time with property to which the amount subject to the tax charge is attributable. Where an asset transferred into settlement, or income that has been accumulated, is