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Back to basics: Section 260 holdover relief

Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.

The purpose of s 260 gift relief

Relief under TCGA 1992 s 260 (‘s 260 relief’) is available on lifetime transfers that are immediately chargeable to IHT and to certain other transfers as set out below. The effect of the relief if available and claimed is broadly to defer all or part of the CGT liability which would otherwise arise on the disposal of a chargeable asset normally until a later disposal by the recipient of the gift. Essentially the gain is passed onto the recipient as well as the gift itself.

Claims for reliefs under s 260 most commonly arise when transfers are made to and from trusts. Most lifetime gifts made...

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