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What are the consequences of gifting property to a UK non-resident trust?

Q: A UK Client is gifting property to a UK non-resident trust; can the gain be held over, and what are the consequences?

A: If a hold over claim under TCGA92 s260 could be made by the donor, then despite the donee being non-resident, the gain can be held over under TCGA92 s261ZA (all disposals since 5/4/2015).

On disposal by the transferee, rather than the gain being held-over, the transferee trust will be treated as having disposed of the asset on the day it was transferred from the UK.