Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Other news

18 March 2003
Issue: 3899 / Categories: News , IR35
Supplementary note concerning the article by Mark McLaughlin and Michael Dawson in Taxation, 6 February 2003 at page 424

Arthur's Grand Finale


The article 'Arthur's Grand Finale' presented a case study on capital gains tax planning for a temporary non-resident working abroad and offered the possibility of rolling over a gain on a trading asset into a property for furnished holiday letting after acquiring non-residence. This part of the planning holds good but a reader has pointed out that the further suggestion in the article that the property for holiday letting could later be sold without capital gains tax liability if the taxpayer were to return to the United Kingdom within five years runs foul of section 10A(3)(d) Taxation of Chargeable Gains Act 1992. That subsection contains a provision specifically to include any asset within the charge under section 10A if gains have been rolled over into that asset under section 152(1)(b) of the Act by reference to any 'relevant...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon