The shares were gifted around 5 years ago but unfortunately they did not think anything of it, until very recently. Given the S43(1) time limit of 4 years, they will now be submitting a late Claim.
Luke’s link to HMRC’s manual CG66889, refers to ‘Consequential Claims’. The last para refers to ‘the analogous provisions in TMA70 S36(3)’. The wording of the para would appear to suggest that the provisions permit hold-over relief to be given for a late claim due to carelessness (via HMRC’s Assessment process), providing the Transferee as not disposed of the gifted shares. Or have I misunderstood it?
My answers
Thank you all.
The shares were gifted around 5 years ago but unfortunately they did not think anything of it, until very recently. Given the S43(1) time limit of 4 years, they will now be submitting a late Claim.
Luke’s link to HMRC’s manual CG66889, refers to ‘Consequential Claims’. The last para refers to ‘the analogous provisions in TMA70 S36(3)’. The wording of the para would appear to suggest that the provisions permit hold-over relief to be given for a late claim due to carelessness (via HMRC’s Assessment process), providing the Transferee as not disposed of the gifted shares. Or have I misunderstood it?
Many thanks good people.
Much appreciated.