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s260 holdover

Available to companies?

I'm pretty certain of the answer, but the sums are large so need to be absolutely certain (if possible). The wording of TCGA 92 s260 is pretty unambiguous. Nevertheless, are there any circumstances in which a company could claim s260 holdover relief on transfer of a chargeable asset? In the instant case, the shares of the transferor company are wholly-owned by an IIP trust.


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14th Feb 2018 09:53

S260 applies to individuals and trusts - not companies. If a company has made a transfer of value one needs to consider income tax implications as well as corporation tax on capital gains and inheritance tax.

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