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Does an associated disposal have to be 100%?

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I have a client that has 100% of the shares in a trading company. That company rents a commercial premises personally owned by that client. My client wishes to slow down at work and has recieved an offer from a third party to buy half the shares in the trading company and half the building. The shares qualify for business asset disposal relief. What I am unsure of, is does the disposal of the building qualify as an associated disposal as only 50% of it is being sold? I've been reading the guidence and can only find reference to the percentage of the main buisness asset (the shares), nothing on the percentage of the associated disposal. All help will be much appreciated, thank you.

 

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By Tax Dragon
30th Sep 2020 10:27

As ever, the answer is in the law.

Try s21 TCGA. Hone in on s21(2)(a). I'm sure you can see what specific words to hone in on further.

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Hallerud at Easter
By DJKL
30th Sep 2020 10:33

You mention rent so you might anyway want to consider this article.

https://www.taxinsider.co.uk/charging-rent-for-business-premises-a-cgt-p...

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