Readers’ forum: Is it possible to claim holdover relief where there is no gain?

I was interested to read in Malcolm Gunn and Fred Butler’s article ‘My claim for your tax bill’ (Taxation 24 October 2024) that a claim should be for holdover relief where there is no gain. This was in the context of a gift to an individual of business assets where TCGA 1992 s 165 allows for the gain to be heldover. TCGA 1992 s 165(10) allows for any inheritance tax that is payable on the gift to be deducted from the capital gain on disposal of the asset by the recipient where a claim for holdover relief under s 165 has been made.

In this case this would be any inheritance tax due because the donor died within seven years of the gift. The article states: ‘There may be cases where no capital gain arises so no holdover claim is required.’

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