S260 Holdover Relief

Shares in an investment company

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I have a client who is thinking of transferring shares in an investment company out of a trust to an individual.  S260 takes precedence over S165, which wouldn't be applicable anyway as it is not a trading company.  My opinion is that as the transfer to the individual would be liable to IHT, S260 holdover could be claimed for CGT.  A second opinion would be appreciated.

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By leeanthonyblackshaw
01st Nov 2022 11:17

If we turn the question on its head; what, in the wording of s260, do you worry might not apply (assuming you are not within three months of a ten year anniversary and that the beneficiary is UK resident)?

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