CG17920 - Taper relief: anti-avoidance rules: example


An individual acquired shares in a dormant company in May 1998. In May 2000 he acquired assets which he used in his own trade until May 2001 when he transferred the assets to the company and it began to trade. Relief under TCGA92/S165 was claimed to defer the tax charge on the transfer of the assets. The commencement of trade by the company in May 2001 is a relevant change of activity within paragraph 11(3). The shares are disposed of on 28 March 2002. The period before May 2001 is treated as a period that does not count for taper relief. The qualifying holding period is therefore May 2001 to 28 March 2002.