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HMRC internal manual

Capital Gains Manual

Gifts: hold-over relief: assessing the donor

Where hold-over relief has been claimed, you reduce the donee’s acquisition cost by the amount of the held-over gain. That gain will then be recovered by assessing the donee, if they:

  • dispose of the asset


  • become non-resident.

In certain circumstances, however, you recover the held-over gain by assessing the donor.

Tax unpaid by NR donee

Where you have assessed a donee who has become non-resident, see CG67286, but the tax remains unpaid 12 months after the date it became payable, you can assess the donor in the name of the donee. You cannot however make such an assessment more than six years after the end of the year of assessment in which the original disposal which gave rise to the hold- over claim occurred.

Liaison with Collector

You can assess the donor in cases where you have already assessed a donee who has become non-resident, and the tax has not been paid. You will be told by the Collector when tax has not been paid in such cases.