CG17921a - Taper relief: anti-avoidance rules - periods of inactivity - relevant period of ownership

Where TCGA92/SchA1/Para11A applies, the start point of the relevant period of ownership can be more than ten years before the date of disposal. But the relevant period of ownership cannot be more than ten years, nor can the start date precede 6 April 1998 or the date of acquisition of the asset (TCGA92/SchA1/Para2). This can be illustrated by a simple example.

Example

Amarjeet acquired shares in an active close company on 15 February 1999. These are disposed of on 15 May 2010. The company was close throughout but inactive between 15 June 2001 and 15 March 2002 and this period will not count in working out the relevant period of ownership. The relevant period of ownership will therefore be the combined periods from 16 March 2002 to 15 May 2010 and 15 August 1999 (not 15 February 1999) to 14 June 2001, being 10 years ending with 15 May 2010.

The way in which periods that do not count affect the qualifying holding period and relevant period of ownership for paragraph 11A purposes is therefore the same as for TCGA92/SchA1/Para10, see CG17928.