CG17897 - Taper relief: qualifying holding period: Taper relief does not apply to disposals before 6 April 1998 or after 6 April 2008

The basic rule is that the qualifying holding period for an asset is the period between

• the later of 6 April 1998 and the date of acquisition of the asset,

and

• the date of disposal of the asset, see CG17900.

This basic rule is subject to several modifications

• if the asset was held before 17 March 1998 and at 6 April 1998 the qualifying holding period may be increased by one year, see CG17901
• if the asset was acquired at no gain/no loss from a spouse or civil partner under TCGA92/S58 the qualifying holding period includes the period that the spouse or civil partner held the asset, see CG17906
• there are anti-avoidance rules that exclude certain periods from the qualifying holding period where

• there is limited exposure to fluctuations in the value of the asset
• there is a change of activity by a company
• there is a period when a company is inactive

or

• there is a shift of value between one asset and another see CG17915 to CG17923

• except in the case of shares allocated to employees under the Enterprise Management Initiatives scheme, see CG 56440, where an asset is acquired by the exercise of an option the qualifying holding period is determined by reference to the exercise of the option and not by reference to the grant of the option, see CG17908
• where assets have merged or divided and the asset that is disposed of derives some part of its value from an earlier asset in the same ownership the qualifying holding period may be extended, see CG17909
• where the gain on an asset would have accrued on a disposal or other event but is postponed until the happening of a later event the qualifying holding period (and the rate of taper) is determined by reference to the date of disposal or other earlier event and not by reference to the time of accrual, see CG17911
• where shares are acquired from the reconstruction of a mutual business the qualifying holding period cannot begin earlier than the date of issue of the shares, see CG17914
• except in the case of a transfer between spouses or between civil partners of each other, where an asset has been acquired in a no gain/no loss transaction the holding period begins on the date of that transaction, see CG17907.