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Where an asset is disposed of, under what circumstances should the gain be split so that taper relief is based upon different qualifying holding periods depending on when expenditure was incurred?
Where an asset is disposed of under what circumstances should the gain be split so that taper relief is based upon different qualifying holding periods depending on when expenditure was incurred?
The only specific legislation in the taper relief provisions seems to be TCGA 1992 Sch A1 para 14 and I wonder if this applies in the circumstances where in respect of land a share is acquired initially say one third and a further share perhaps another third is acquired at a later date. Would this be an instance where the two-thirds that is eventually sold was derived from other assets and the taper relief for the whole asset is then based upon the date that the first third was acquired? Would the situation be different where there is simply enhancement expenditure?
Query T16 733 — Backwoodsman.
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