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ANDY WELLS considers the effect of the 'trading company' definition on the capital gains tax gifts relief.
SUBSTANTIAL QUALIFICATION, the article by Paul Hodge and Matt Reid in Taxation, 20 January 2005, p370 focused on business asset taper relief, but the matters discussed are also vital if relief is to be claimed under TCGA 1992, s 165 on a disposal of shares by way of gift, (see s 165(8)(aa) inserted by FA 2004 with effect from the current tax year).
ANDY WELLS considers the effect of the 'trading company' definition on the capital gains tax gifts relief.
SUBSTANTIAL QUALIFICATION the article by Paul Hodge and Matt Reid in Taxation 20 January 2005 p370 focused on business asset taper relief but the matters discussed are also vital if relief is to be claimed under TCGA 1992 s 165 on a disposal of shares by way of gift (see s 165(8)(aa) inserted by FA 2004 with effect from the current tax year).
The authors quite rightly drew attention to the Inland Revenue's attitude at district level to situations in which the company concerned holds a large cash balance. The article in Tax Bulletin 62 gave the Revenue's understanding of 'substantial' with some examples of things that may be taken into account. Tax Bulletin articles do carry some weight as they represent a published view...
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