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HMRC internal manual

Capital Gains Manual

Gifts: hold-over relief: assessing the donee

Donee becoming NR

Where an assessment to recover all or part of a held-over gain is necessary you should make it on the donee at their latest known address.

In such cases you should check whether or not the tax is paid so that an alternative assessment on the donor may be made where appropriate, see CG67360+.

Reliefs / exemptions

A donee who has gone non-resident before disposing of the asset is treated as if a chargeable gain had accrued to them immediately before they became non-resident, see CG67286. They are not, however, deemed to have disposed of the asset itself.

Therefore they are entitled to have any available part of their annual exempt amount or any allowable losses set against the gain. They cannot, however, set reliefs such as

  • private residence relief, see CG64200+


  • replacement of business assets relief, see CG60250+

against this gain.

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Subsequent disposal of asset after emigration

Assessing the donee to recover the held-over gain affects the computation of any gain if they subsequently dispose of the asset. In these cases, their acquisition cost is no longer reduced by the amount of the gain which had been held-over, see CG66980 and CG67090.

You can only assess a non-resident who disposes of an asset in certain circumstances. CG25500+ and CG42100+ tell you about these.