CG65442 - Restriction of private residence relief: trustees: claim for gift hold-over relief made after claim for private residence relief

TCGA92/S226A

Where

• a claim for gift hold-over relief under TCGA92/S260 is made in relation to any earlier disposal or disposals, the latest of which was made on or after 10 December 2003

and

• the claim for gift hold-over relief is made after the making of a claim for private residence relief in respect of the later disposal

assume that private residence relief was never available to the transferors in respect of the later disposal and make an assessment on the transferors accordingly. For this purpose you can ignore any limitation on the time within which any adjustment may be made (TCGA92/S226A (3) and (4)).